i
or
E (R
i
) R
I
i
x (E(R
M
) - R
I
)
Where:
R
I
the risk Iree rate
E|R
i
| the expected return on stock i
R
M
the expected return on the market portIolio
i
the beta oI the individual security
Should an investor decide that the preIerred risk-return combination is the risk-Iree asset and the
market portIolio, this would be calculated as beta () oI M and (1 ) oI the risk Iree rate, R
I
.
The development of pension systems in Europe and the role of governance, risk management and external consultants
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The expected return would be:
(1 ) R
I
x E(R
M
)
or
R
I
x (E(R
M
) - R
I
)
The investor return would thereIore be a premium over the risk-Iree rate, which would be equal
to the market risk premium` multiplied by .
In the equation below, the expected return uses the Beta coeIIicient Ior security i` to measure the
variance oI the return on stock i` with that oI the market portIolio.
i
Cov(R
i
,R
M
)
Var (R
M
)
or
i
Corr
iM
x SD
iM
/ SD
M
The CAPM equation is thus:
E (R
i
) R
I
i
x (E(R
M
) - R
I
)
Where:
E(R
i
) the required return Ior the individual security
R
I
the risk-Iree rate oI return
i
the beta oI the individual security
R
M
the expected return on the market portIolio
(R
M
- R
I
) is called the market risk premium
The CAPM equation can thus be used to Iind the value oI one oI the variables listed above,
provided that the value oI the other variables is known. An example oI this is as Iollows:
CAPM example 1
The required return on a stock with a risk-Iree rate oI 8, an expected return on the market
portIolio oI 12, and a Beta oI 2 would be calculated as Iollows:
E(R
i
) R
I
i
(R
M
- R
I
)
E(R
i
) 8 2(12 - 8)
E(R
i
) 16
The required rate oI return should at this stage be compared to the expected rate oI return and a
decision made as to invest in the stock or not. An investment would only be made iI the expected
rate oI return exceeded the required rate oI return.
CAPM example 2
Alternatively, the calculation oI beta on a stock with an expected return oI 12, a risk-Iree rate oI
4, and an expected return on the market portIolio oI 10 would be conducted as Iollows:
12 4
i
(10 - 4)
i
12 - 4
10 - 4
i
1.33
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The objective oI a pension Iund manager should thus be to obtain a required return oI 2 or 3
above the risk Iree rate through the diversiIication oI risk using asset classes that are relatively
uncorrelated such as equities and bonds.
The use oI the CAPM proves that investment in a series oI individual stocks is not necessarily a
wise approach to risk management. It is possible to duplicate the reward and risk characteristics
oI any security just by using the right mix oI cash with the appropriate asset class or group oI
securities that has high correlation with securities in the same group.
Modern portIolio theory has helped pension Iunds steer towards the relative risk properties oI
securities and into the world oI diversiIication and beta. With the the improvement in computer
systems it is now possible to systematically identiIy risk Iactors an develop indexation and
specialization by country, regions, sector and market cap. To this end, Iund mangers` that
practice MPT tend to avoid stocks, and instead build portIolios out oI low cost index Iunds.
The CAPM has its limitations as a model Ior pension management in that results are Iocused on
static solutions to portIolio problems and oIten ignore the time dimension. There is an
argument Ior the CAPM to be revamped in order to incorporate market movements, and their
impact on all beta and manager decisions. To achieve this it is necessary Ior Iund managers to
establish a set oI rules that relate to speciIic states oI the world. An optimal portIolio needs to
be developed Ior each state, supplemented by a dynamic strategy that repositions the portIolio
as external Iactors move the market Irom one state to the next. This Iactor analysis needs to be
a systematic process that generates consistent recommendations based on sound rational and
inIormed judgement. The aim is thus to create a process that it is more about optimal strategies
than optimal portIolios.
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Part III
Review of EU pension frameworks
Chapter 6 The move to cross-border pension schemes
Institutions that provide occupational pension products were one oI the last to enjoy the
beneIits oI an Internal Market legislative Iramework. There has been a concerted move
however over recent years to introduce harmonised and advanced risk-oriented prudential
Irameworks in other parts oI the Iinancial sector; the most notable being the global Basle II
accord Ior credit institutions. Such supervisory Irameworks, incorporating the latest
developments in Iinance, actuarial science and risk management, intend to promote a level
playing Iield across countries. The road to harmony however is not such a smooth path; the
creation oI a pan-European pension Iramework is a large undertaking Ior EU legislators with
many competing constituencies and great potential Ior conIlicts oI interest. Change thereIore, is
best in an evolutionary Iorm.
Lewin`s force-field analysis for change
In order to address the mounting problem oI an ageing society, the European Parliament
realized that it would have to bring about change on a broad scale across the community. In
any situation that involves a degree oI upheaval there are always Iorces that support and resist
change. Lewin (1947)
1
developed the Iorce Iield analysis` as a Iramework Ior evaluating the
variables involved in planning and implementing a change program. To achieve change Lewin
argued that there is a need to address the status quo` or current stand-oII in a given system
through the introduction oI intervening variables in order to reposition both short-term and
long-term goals.
When applying the Iorce Iield analysis` Iramework to the European pension arena, it is
necessary to identiIy the opposing Iorces Ior change in the Iirst instance:
1. Driving forces for change in the pension industry
Forces that drive in the direction Ior change in the pension industry would include new
regulation, European directives, technology advancement, and developments in corporate
governance.
2. Restraining forces for change in the pension industry
Restraining Iorces are those that act to restrain or decrease the driving Iorces. In the pensions
industry they would include apathy, hostility, Member State social & labour laws, and existing
tax legislation.
1
Lewin, K. (Ed.). (1947). Force Field Analvsis and Diagram, Retrieved Irom
http://www.valuebasedmanagement.net/methodslewinIorceIieldanalysis.html
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A situation oI Equilibrium is reached when the sum oI the driving Iorces equals the sum oI the
restraining Iorces as shown in Diagram 6.1 below.
Diagram 6.1: The force-fieId anaIysis
Forces for change Forces resisting change
Driving forces Restraining forces
This position oI equilibrium can be altered by changes in the relationship between the driving
and the restraining Iorces. Lewin argued that 'where there is equilibrium between the two sets
oI Iorces there will be no change, and thereIore in order Ior change to occur the driving Iorce
must exceed the restraining Iorce.
The Iirst stage in the process is to unIreeze` the situation by initiating some new measures oI
change. By introducing new regulation and issuing European directives on the harmonizing oI
pension systems across Europe the EC Parliament increased the driving Iorces Ior change.
However as a result oI such pressure, certain Member States entrenched themselves behind
their national social and labour laws which oIIer each country a certain degree oI protection
Irom Brussels; a new position oI equilibrium was thus created. The process oI overcoming
inertia had thereIore to be addressed once again through the introduction oI additional Iorces
Ior change or the elimination oI restraining Iorces in order to allay the Iears oI Member States.
This was achieved by the development oI a series oI open discussions across EC States inviting
Ieedback on all issues oI contention. The challenge Ior the EU was thereaIter to crystallize the
new mindset and reIreeze` the situation as the Iinal stage in the change process.
The primary aim oI such change is to deliver greater harmony in the pension systems across
Europe in order to promote occupational scheme development and the mobility oI labour.
Through the evaluation oI the balance oI power involved in the pension arena the EC
Parliament identiIied the key stakeholders and developed a strategy to inIluence the change
process. A sense oI urgency was created surrounding the problem oI an ageing population. A
series oI directives were issued in terms oI harmonizing legislation on pensions; these included
the IORP directive (2003)
1
and the Solvency II directive in (2005)
2
. The change was driven by
1
IORP Directive, DIRECTIVE 2003//Stat. 1-12 (2003), http://eur-lex.europa.eu//LexUriServ.do?uriCELEX:32003L0041:EN:HTML.
2
Commission oI the European Communities. (2007, July 10). Directive of the European Parliament and of the Council on the taking-up and
pursuit of the business of Insurance and Reinsurance- Solvencv II. Retrieved Irom The European Commission website:
http://www.europeanlawmonitor.org///text.pdI
The development of pension systems in Europe and the role of governance, risk management and external consultants
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71
CEIOPS, the European pension supervisors, which issued a protocol that provided Ior a
Iramework Ior the cooperation oI supervisory authorities. The directives clariIied how
inIormation would be shared among member states and outlined the required standards Ior best
practice in pension Iund management. The objective was to demonstrate how things would be
diIIerent Irom the past and how the provision oI healthy occupational schemes could be
structured Ior the Iuture.
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Chapter 7 Institutions for Occupational Retirement Provisions (IORP)
With the onset oI globalization and the mobility oI labour playing an increasingly important
role in the employment oI personnel across Europe, it has become desirable to have an
occupational pension system that is acceptable across the borders oI EU Member States. On 11
May 1999, the European Commission announced the establishment oI The Institutions Ior
Occupational Retirement Provisions` or IORP, with a view to ensuring both the security and
the aIIordability oI pension schemes in Member States.
A} The a|ms and structure of an |0RP
An IORP is deIined in the Directive as an institution that operates separately Irom any
sponsoring undertaking Ior the purpose oI providing retirement beneIits in the context oI an
occupational activity. The IORP is used as a vehicle to receive contributions Irom a sponsoring
undertaking or employer with a view to Iunding their member`s pension liabilities.
The Directive on the activities and supervision oI IORP`s was published in the OIIicial EU
Journal on 23 September 2003 (IORP 2003)
1
. All member states were obliged to have
implemented the Directive by 23 September 2005. The Directive provides a regulatory and
supervisory Iramework Ior cross-border pension services. It acts as a Ioundation in the creation
oI a common market Ior the provision oI occupational pensions throughout the European
Union.
The Directive equips Iinancial services providers with their own set oI principle-based rules in
the domain oI occupational pensions. As oI 30 December 2005, the IORP Directive allows
institutions located in one EU member state to accept pension Iund contributions Irom
institutions in another EU member state. For a domestic pension scheme to engage in cross-
border activity, it must be authorized and approved by the national Pension Regulator`. To this
end the Directive argues Ior the minimization oI red tape when taking up cross-border activity
in order to ensure that an authorized IORP can automatically qualiIy Ior EIORP status.
The aims oI the Directive are to provide security to Iuture pensioners via a minimum common
standard oI governance, and to create a platIorm Ior a level-playing Iield in terms oI the sale oI
schemes across EU state borders. The Directive recognizes that Member States may wish to
impose diIIerent levels oI security on employer pension Iunds in accordance with their culture
oI risk. With this in mind, the Directive also grants Member States the right to decide upon
their level oI compliance, in accordance with the principle oI subsidiarity and to retain Iull
responsibility Ior the organisation oI their pension systems along with Iull responsibility Ior the
role and Iunctions oI the various institutions providing occupational retirement beneIits.
The Directive provides Ior an institution registered in one Member State as an IORP, to operate
in other EU member countries provided that it Iully respects the provisions oI the occupational
pension-related social and labour law` (SLL) in Iorce in the host Member State. This means
that the level oI technical provisions and security mechanisms relating to the host country
prudential Iramework must be applied to the IORP, even iI such requirements are not part oI its
home country legislation. The Directive is also clear on the issues oI pension Iund
commitments to their members, in that all liabilities should remain segmented in the diIIerent
countries where the pension sponsors provide their services.
1
IORP Directive, DIRECTIVE 2003//Stat. 1-12 (2003), http://eur-lex.europa.eu//LexUriServ.do?uriCELEX:32003L0041:EN:HTML.
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A European passport has thus been established Ior institutions involved in the creation oI
employer-sponsored pension schemes, which allows them to oIIer their services on a European
scale. The IORP Directive Iocuses on the Iollowing three issues:
To ensure a high degree oI security oI pensions and oI protection oI the beneIiciaries,
through a qualitative approach combining a set oI basic prudential rules with qualitative
rules on pension Iund liabilities;
To make supplementary pensions more aIIordable by avoiding unduly restrictive
prudential rules Ior investment that would result in lower returns;
To allow pension Iunds to provide their services in another Member State, thereby
making it possible to have cross-border membership so as to reduce costs and to
encourage cross-border mobility within the Iirm.
A primary objective oI the IORP Directive is to secure closer co-operation between economic
policy makers and market Iorces in order to mitigate the levels oI risk and create greater
eIIiciency in the pension industry. The aim is to create a prudential Iramework Ior the
management oI pensions whilst at the same time liberating institutions in terms oI their
investment policy so that they may beneIit Irom the greater depth and liquidity oI the capital
markets. Merlin (2000)
1
argued that the ability oI pension Iunds to invest in equity and risk-
capital markets would result in a boost to the EU economy through the Iostering oI growth and
employment.
Occupational pension Iunds are one oI the largest institutional investors in Europe. Recent
estimates indicate that the total occupational pension Iund assets under management in the EU
are circa Euro 2 trillion in value; these assets are concentrated mainly in the UK, the
Netherlands, Germany and Spain. The total equity holdings oI the pension Iund portIolio stands
at just over Euro 1 trillion, representing on average 48 oI total assets. The total bond
portIolios holdings amount to Euro 688 billion or 32 oI total assets under management
(SteIIen 2008)
2
.
1. Pooling of assets and liabilities
For an IORP to realize its Iull potential it must be able to pool assets and liabilities, relating to
pension schemes across two or more Member States, into a single investment vehicle.
Ambrosius (2008)
3
outlined the Iollowing beneIits oI asset pooling as a result oI the IORP
Directive:
2. Quantitative benefits
Economies oI Scale;
Cost Savings;
Netting oI Cash Flows.
1
Merlin, M. (Ed.). (2000, October 23). INSTITUTIONS FOR OCCUPATIONAL RETIREMENT PROJISION. COMMISSION PROPOSES
DIRECTIJE. Retrieved Irom http://ec.europa.eu/market///mn16.htm
2
SteIIen, T. (2008, November 19). Check against deliverv. Speech presented at European Pension Funds Congress, FrankIurt.
3
Ambrosius, J. (2008, November 18). Asset Pooling for Pension Funds. Speech presented at European Pension Funds Congress, FrankIurt.
The development of pension systems in Europe and the role of governance, risk management and external consultants
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3. Qualitative benefits
Improved Investment DiversiIication;
Enhanced Investment Choice;
Access to Larger Universe oI Managers;
More Consistent Investment Approach;
Consolidated Reporting;
Higher Transparency;
Leaner and More EIIicient Administrative Processes.
It is the aim oI the IORP Directive to harmonize the occupational pension systems oI member
countries in terms oI the supply oI suitable Iinancial pension products. This in turn paves the
way Ior multinational Iirms to harmonize the investment side oI their pension business under a
single legal entity by choosing a site Ior their operations in a given EU-member country. By
Iacilitating this, the IORP Directive will potentially lead to signiIicant economies oI scale Ior
these institutions, thereby creating the conditions Ior managing occupational pension savings in
a cost eIIective manner.
4. Structure of a cross-border IORP
The diagram bellows illustrates how two or more local pension schemes can be integrated into
a centrally managed cross-border IORP. The diagram shows the structure oI an IORP under the
banner oI a single legal entity as opposed to plans that are either managed individually in each
country, or alternatively with the assets in a shared investment vehicle but with separate legal
entities.
Diagram 7.1: Structure of a cross-border IORP
Source: Mercer 2008
In the above model, a multinational company pension scheme is Iinancially regulated by the
'home country, which is in this case, Ireland. Each part oI the scheme representing members
located in either the Netherlands, Ireland or the UK, must comply with the tax, social and labor
laws oI that country, otherwise known as the "host" countries. The assets and liabilities
however are pooled at the home country level.
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} Sovernance - The 6omm|ttee of European |nsurance and 0ccupat|ona| Pens|ons 8uperv|sors
(6E|0P8}
As an EU Iinancial services supervisory authority, CEIOPS is involved in the development oI a
cooperative Iramework between Member States to ensure that conditions emerge Ior
unproblematic cross-border activity in the occupational pensions sector. Supervisory co-
operation was agreed upon by all EU Member States with the Budapest Protocol, which
attempted to establish the rules and regulations under which pensions supervisors oI IORP`s
should operate. The general principles oI cooperation oI the relevant authorities were outlined
in terms oI what inIormation is required Irom either home or local regulators when authorities
Iind there is incompatibility between legal Irameworks where an IORP or sponsors want to get
approval to operate in a diIIerent state (CEIOPS 2009)
1
.
CEIOPS plays a signiIicant role in identiIying, and improving the transparency oI, national
SLL issues that aIIect the Iield oI pan-European occupational pension Iunds. To this end a
comparative assessment oI the Iinancial requirements Ior IORPs in the EEA countries was
conducted in March 08. The objective was to Iurther the development oI the European solvency
Iramework Ior IORPs by identiIying the range oI technical provisions and security mechanisms
in the European occupational pension sector (CEIOPS Mar 08). The report outlines the
diIIerences between the various local prudential regimes Ior IORPs and details the parameters
which are used Ior the actuarial calculations in each country.
The existing prudential Irameworks in the EEA are very diverse with diIIerences relating to
complex technical aspects and in part reIlect provisions in national SLL. Many Member States
are only now beginning to come to grips with the nature and operation oI their own systems in
relation to the IORP Directive. The creation oI a common, EU-wide Iramework is an additional
step Iurther, wherein it is necessary Ior Member States to understand each others` systems as
well as understanding the impact oI the IORP Directive. National SLL may determine the
content oI the pension promise, or may set minimum requirements, such as inIlation
protection, maximum discount rates, mortality assumptions, increase in premiums, reduction in
accrued rights, return guarantees, sponsor commitment and insolvency protection. These
requirements inIluence the level oI the technical provisions to be held by the IORP and the
Iunctioning oI security mechanisms (CEIOPS, Mar 08)
2
.
1. Regulatory abitrage
IORP`s may be tempted to use regulatory arbitrage in the selection oI their nominal home
country base, with a view to lowering the costs involved in complying with Iinancial
requirements. However there are many issues Ior employers or IORP`s to consider when
choosing where to base themselves in order to take advantage oI a multi-country IORP
platIorm. These include:
1
CEIOPS. (n.d.). (2009). Budapest Protocol (Consultation Paper No. 38). Retrieved Irom http://www.ceiops.eu//////CP-38-09-Budapest-
protocol.pdI
2
CEIOPS (Ed.). (2008, April). Survev on Fullv Funded, Technical Provisions and Securitv Mechanisms in the European Occupational
Pension Sector. Retrieved Irom
http://www.ceiops.eu/media/docman/publicIiles/publications/submissionstotheec/ReportonFundSecMech.pdI
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The availability oI good governance;
The ability to ring-Ience assets;
The extent oI solidarity permitted.
A careIul analysis oI the situation is required in order to successIully establish a cross-
border IORP; one which addresses all the Iacts and garners support Irom both the plan
sponsor and the members.
2. Funding rules for IORP`s
Adequate Iunding requirements and sound risk management practices are considered
essential to saIeguarding beneIiciaries` interests. In the case oI cross-border schemes, the
binding principle is Ior pension Iunds to be 'Iully-Iunded at all times and have an actuarial
valuation each year to make sure that remains the case. This target may not be viable in times
oI Iinancial crisis and therein presents an obstacle to the success oI the IORP Directive.
Although the Directive requires that IORP`s undertake a high level oI protection in terms oI
their commitments to member`s pensions, it is important that it also allows Ior temporary
underIunding should a suitable recovery plan be presented.
The Directive deIines the Iully Iunded status` oI schemes as being in possession oI suIIicient
and appropriate assets` to honour pension liabilities. The Iirst step in this process involves the
calculation by the pension plan administrator oI all projected payments to pensioners in Iuture
years. In order to be Iully Iunded, the plan must have enough capital contributions Irom the
plan sponsor, plus returns Irom investments, to pay those claims. Funding standards range Irom
speciIic quantitative rules with reserving, solvency buIIers and stress testing, to stating
precisely the liabilities to be covered on a principles based approach.
A Iurther qualiIication oI the concept oI mutual recognition` implies that, should a national
standard with regards Iunding rules be agreed upon in a given Member State, it must thereaIter
be accepted by other Member States without question. The EFRP (2005)
1
points out that
contradictions in the understanding oI the rules may occur wherein a home State grants
temporary underIunding to it`s domestic IORP`s and yet requires the Iully Iunded status` to
apply to the cross-border operations. This type oI anomaly would suggest that the techniques
Ior distinguishing domestic Irom cross-border operations need to be approached with particular
care.
Advanced Iunding may also be arranged by IORP`s whereby money is set aside separate Irom
any sponsor Ior payment oI the Iuture beneIits arising under the scheme. Whether Iunding is
provided by IORP`s or the schemes sponsor, there is concern that heavy Iunding
requirements may impose inappropriate large up-Iront payments that are not needed
because oI other security mechanisms already in place, thereby discouraging deIined
beneIit pension provision.
Keating (2009)
2
questioned iI the risk management interventions used by pension Iunds have
proven counter-productive in their application. Although pension contracts have long terms,
1
EFRP (Ed.). (n.d.). Annual Report 2005. Retrieved Irom http://www.eIrp.org//publications/20Annual20Report202005.pdI
2
Keating, C. (Ed.). (2009, November 2). 'Manv of our risk management interventions proved counter-productive in use`. Retrieved Irom
http://www.ipe.com//oI-our-risk-management-interventions-proved-counter-productive-in-use33153.php?articlepage1
The development of pension systems in Europe and the role of governance, risk management and external consultants
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risk management techniques operate on immediate, present values, and thus present a number
oI diIIiculties. Keating argues that: 'the long-term optimal strategy is only equal to the
progression oI optimal short-term strategies in extremely limited circumstances, which are most
unlikely to be satisIied in practice. One variant oI this arises Irom the European Pensions
Directive (IORP) which introduced a requirement Ior Iull Iunding at all times, notwithstanding
the reality that the only point in time at which this level oI Iunding is strictly necessary is when
the pension is due and payable. This requirement brings with it costs and consequences. In the
light oI the Iinancial crisis it may well be time to re-examine the basis Ior current pension
Iunding levels.
3. Particulars of the IORP
The IORP Directive does not apply to book reserve` pension systems wherein a reserve
is set up in the account oI the sponsor and a portion oI the company`s assets are
deemed to be set aside Ior the provision oI beneIits. Nor does it apply to pay-as-you-go
systems in which current beneIits are paid Irom current contributions into the system, with no
advanced Iunding as a rule. Additionally the IORP Directive does not apply to insurance-based
pension schemes wherein direct insurance arrangement premiums are paid to the insurer
and beneIits paid by the insurer to the beneIiciaries as they are deIined in the insurance
contract (CEIOPS 2008)
1
. To such arrangements the Third LiIe Directive (1992)
2
is applicable.
The IORP Directive is geared towards DB pension schemes, whether exclusively or in
combination with DC schemes. However, the Directive requirement Ior technical provisions
to be estimated and held does not apply to pure DC schemes.
4. EU - Social and labour law
Member States have identiIied Iour common principles that should underpin a pension
supervisory Iramework:
Risk-based approach to pension supervision individual countries tailor the scope
and intensity oI supervision to their appraisal oI risk Iaced by the IORP.
Market-consistency in the valuation oI an IORP`s assets and liabilities Ior supervisory
purposes in order to Iacilitate realistic solvency monitoring. This means that market
prices are used where available (mark-to-market), otherwise values may be
determined by a modelling approach (mark-to-model).
Transparency an IORP is open to scrutiny on all aspects oI how its Iinancial position
1
CEIOPS (Ed.). (2008, April). Survev on Fullv Funded, Technical Provisions and Securitv Mechanisms in the European Occupational
Pension Sector. Retrieved Irom
http://www.ceiops.eu/media/docman/publicIiles/publications/submissionstotheec/ReportonFundSecMech.pdI
2
Third LiIe Directive, Third Council Directive 92//COUNCIL DIRECTIVE 92//EEC 1 (1992),
http://209.85.129.132/?qcache:oD6bkMWSIoMJ:www.sigortacilik.gov.tr/YD/ABD/.01-Hayat/.docCOUNCILDIRECTIVE92/
/EECoI10November1992&hlIr&ctclnk&cd1&glIr.
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is determined.
Proportionality - supervisory requirements are applied in a manner proportionate to
the nature, complexity and scale oI the IORP`s inherent risks.
The deIinition and scope oI social and labor law is a matter oI concern Ior a number oI
Member States. Verhaegen in an interview with WoolIe Irom IPE (2009)
1
, argued that the
situation had become problematic in terms oI the boundary between home state prudential
protection and host state social and labour protection. She advocated that it was the role oI
CEIOPS to help solve problems associated with cross-border activity, such as those
involving diIIerent legal requirements and potential regulatory and or supervisory gaps and
overlaps.
5. Different types of IORP
With Member States using diIIerent valuation methods and diIIerent security mechanisms to
protect pension beneIits, the task oI ensuring a level playing Iield Ior cross-border IORPs
within Europe is diIIicult. Nevertheless the Directive stipulates that comparable pension
schemes need to be treated comparably across Member States.
There are two types oI distinguishable IORP`s in Europe:
The IORP is an independent legal entity, completely separate Irom the employer, with
Iull recourse to own Iunds. In this case the IORP would make a provision on its balance
sheet to cater Ior biometric risks or to guarantee a certain investment perIormance or
level oI beneIits. Although such a buIIer serves the role oI a shock absorber` in times
oI economic or cyclical crisis, it also carries the burden oI having to tie up capital in
order to IulIil a potential promise to the beneIiciary.
The IORP is set up by the sponsor who therein provides the ultimate pension security to
its employees. The Iuture and economic and Iinancial health oI both the IORP and
sponsor are thus inextricably linked.
It should be noted that there are various Iinancing systems and vehicles in relation to
occupational pension schemes across the EU. As a result, it is possible Ior more than one
system to exist in individual EU Member States.
} Techn|ca| prov|s|ons for |0RP's
IORPS operate as Iinancial institutions with a social purpose. To this end technical provisions
are required that give an indication oI the minimum amount oI assets that IORP`s should
possess in order to honour pension beneIits as and when they Iall due. There are many
variations in the methods and assumptions used by Member States to determine the level oI
technical provisions on issues such as inIlation/salary indexation, mortality assumptions, etc;
1
WoolIe, J. (2009, March 26). Quo vadis IORP? IPE.com. Retrieved Irom http://www.ipe.com//vadis-iorp31268.php?articlepage1
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Assumptions Ior technical provisions are oIten based on best estimates with some countries
incorporating extra saIety margins and prudence in diIIerent components oI the technical
provisions. In particular a market-related discount rate` is employed by most countries to
calculate the present value oI Iuture pension payments. IORP`s recognise as a liability in the
balance sheet the present value oI current and Iuture pension rights oI all their members. In
many instances countries use current risk-Iree market rates to determine their discount rates.
Under the IORP Directive, all IORP`s must hold suIIicient assets to cover technical provisions
i.e. a minimum Iunding ratio oI 100. The Directive does allow Ior periods oI under Iunding
as long as the IORP has a concrete and realistic plan to ensure Iunding is restored. These
requirements derive Irom Articles 15 and 16 oI the Directive. This caveat does not exist
however in the case oI schemes operating cross-border, wherein the Directive requires Iull
Iunding oI technical provisions at all times (see IORP 2003, Article16)
1
.
EU Member States have leaned towards prudent valuation principles in terms oI the presence oI
extra reserves to compensate Ior additional security mechanisms. However such measures are
not easily quantiIiable and thus leave a degree oI uncertainty as to how large the reserves may
be. Table 7.1 below shows the range oI technical provisions provided by EU Member States
(CEIOPS 2008)
2
.
TabIe 7.1 Summary overview - Components of technicaI provisions
Source CEIOPS 2008
1
IORP Directive, DIRECTIVE 2003//Stat. 1-12 (2003), http://eur-lex.europa.eu//LexUriServ.do?uriCELEX:32003L0041:EN:HTML.
2
CEIOPS (Ed.). (2008, April). Survev on Fullv Funded, Technical Provisions and Securitv Mechanisms in the European Occupational
Pension Sector. Retrieved Irom
http://www.ceiops.eu/media/docman/publicIiles/publications/submissionstotheec/ReportonFundSecMech.pdI
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1. Inflation protection and salary indexation
The Iuture purchasing power oI pension beneIiciaries can be protected against the risk oI
inIlation through the indexation oI pension rights. In countries that commit to inIlation
protection and/or salary indexation, provision is made Irom IORP surpluses when available.
Some countries apply conditional inIlation indexation in that protection is granted only on the
provision that the IORP is judged to have suIIicient surpluses in excess oI the technical
provisions.
The CEIOPS paper reveals that iI the actual inIlation or wage growth exceeds the assumption
underlying the technical provisions, then a certain degree oI risk is leIt with the IORP. On the
other hand, should the guarantee be capped, some degree oI inIlation risk is leIt with the
member. This illustrates the need to set realistic inIlation assumptions and supports the
argument Ior an external benchmark such as the Consumer Price Index` to be used to calculate
the inIlation rate.
Table 7.2 shows in which EU countries an allowance Ior inIlation or salary increases must be
made in the technical provisions.
TabIe 7.2: AIIowing for infIation and saIary increases in the reserving method - Active members
Source: CEIOPS 2008
2. Interest rate used to discount the technical provisions
One oI the most important assumptions in calculating technical provisions is the
discount rate. From a market oriented perspective, the applied discount rate should correspond
to the security promised to the beneIiciary. The reason Ior this is that the mark-to-market
value oI a pension liability equals the market price oI the investment portIolio that
generates congruent cash Ilows. It Iollows thereIore that guaranteed pension liabilities should
be discounted at a risk-Iree rate (CEIOPS Mar 08)
1
. The CEIOPS survey shows that only Iour
countries apply the current risk-Iree market interest rate as the discount rate: The Netherlands,
Denmark, Sweden and Portugal. The objective is Ior the discount rate to be chosen prudently
and to take into account the yield oI the corresponding assets held by the institution along
with Iuture investment returns and/or the market yields oI high quality or government bonds.
1
CEIOPS (Ed.). (2008, April). Survev on Fullv Funded, Technical Provisions and Securitv Mechanisms in the European Occupational
Pension Sector. Retrieved Irom
http://www.ceiops.eu/media/docman/publicIiles/publications/submissionstotheec/ReportonFundSecMech.pdI
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Countries such as Spain and Austria use Iixed maximum discount rates set by the government
or the supervisor. Countries that select prudent discount rates below the current risk-Iree rate
will have an increased contribution to their technical provision levels. In countries where the
discount rate is above the current risk-Iree rate, the level oI technical provisions will be reduced
as less money is required to be put in reserve. In general the use oI Iixed discount rates makes
the technical provisions independent oI interest rate changes, i.e. the duration is zero. It should
be noted however that under mark-to-market valuation the duration oI pension liabilities is
substantial; oIten in the range oI 15 to 20 years.
A smaller group oI countries, including Germany, France and Norway, practice additional
prudence by setting a discount rate below the risk Iree market rate in accordance with Article
20 oI the insurance based Third LiIe Directive (1992)
1
. The discount rate does not exceed 60
oI the rate on bond issues by the State in whose currency the contract is denominated.
Fischer (2008)
2
observed that: 'in most countries, responses to emerging issues were measured
and contribute to scheme stability. Nevertheless one should analyse the signs oI stress and take
measures where appropriate. In my view some signs oI such stress indicate structural changes
Iunded pension schemes need to address. For example, given that variations in discount rates
have had such a strong impact on Iunding ratios, reIlects not only short term Iluctuation oI rates
but also the ever longer periods Ior which liabilities have to be calculated Iollowing continuous
increases in liIe expectancy oI members.
Diagram 7.2 shows the average discount rates as applied at the end oI 2006 as well as the 15
year risk Iree interest rates in each country.
Diagram 7.2: Discount rates (end 2006)
Source: CEIOPS 2008
1
Third LiIe Directive, Third Council Directive 92//COUNCIL DIRECTIVE 92//EEC 1 (1992),
http://209.85.129.132/?qcache:oD6bkMWSIoMJ:www.sigortacilik.gov.tr/YD/ABD/.01-Hayat/.docCOUNCILDIRECTIVE92/
/EECoI10November1992&hlIr&ctclnk&cd1&glIr.
2
Fischer, G. (2008, November 19). Role of workplace pensions. Speech presented at European Pension Funds Congress, FrankIurt.
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3. Mortality assumptions
Technical provisions typically Iactor in the liIe expectancy oI scheme members, as set out in
mortality or liIe expectancy tables. Rates are determined by the domestic Iinancial services
industry oI each country in order to calculate scheme member survival probability and therein
biometric risk. The steady improvement oI liIe expectancies in Europe has resulted in many
countries taking the prudent step oI including a mortality trend in their table calculations.
Taking into consideration the observed trend in improving survival rates, rather then applying
current mortality rates, can have a considerable eIIect on technical provisions. The issue oI
longevity is coming to the Iore as Iund administrators oI DB schemes seek to address the
problems associated with meeting commitments to retired members over their liIetime.
4. Expenses
Reservation Ior Iuture expenses increases the size oI the technical provisions. An allowance oI
up to 5 in some cases is made by Member States Ior the Iuture expenses oI the IORP in terms
oI costs related to the administration, asset management and disbursement oI pension rights.
5. Security mechanisms
In accordance with the law oI each Member State, security mechanisms can be used to increase
the security oI the accrued and Iuture expected beneIits and reduce the chances oI any
shortIall in the Iunding level.
Lommen (2008)
1
observes that the Iinancing requirements Ior IORPs are not limited to
technical provisions, in that local prudential regimes also encompass a wide range oI
supplementary security mechanisms. All Member States are obliged to respect the IORP
Directive requirement oI Iully Iunded pension liabilities. Where the IORP underwrites the
liability and does not have sponsor support, it is required to hold additional Iunds in order to
mitigate the risk between the assets and the liabilities. The security mechanisms include:
Regulatory own Iunds and additional solvency buIIers;
Subordinated loans;
Sponsor commitment and increases to contractual premiums/sponsor
contributions;
Guarantee Iunds;
Mechanisms to reduce accrued pension rights;
Reduction oI Iuture conditional inIlation.
Table 7.3 distinguishes between countries that impose mandatory solvency buIIers on the IORP
sponsor and those that do not. These can be sub-divided into ex ante and ex post security
mechanisms.
1
Lommen, J. (Ed.). (2008). IORP II. towards a new solvencv framework? Retrieved Irom
http://www.ipe.com//IItowardsanewsolvencyIramework28781.php?articlepage1
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6. Ex ante security mechanisms - regulatory own funds` and subordinated loans`
Ex ante security mechanisms are Iinanced in advance by IORP`s and kept separate Irom
the sponsoring company. The CEIOPS report identiIies the Netherlands, Belgium,
Germany, France and most Scandinavian countries as territories that incorporate
saIeguards in the Iorm oI regulatory own Iunds`. This buIIer acts as a security mechanism
by ensuring that the pension promise can be honoured in times oI Iinancial distress. These
additional assets are oIten used by the IORP to cover against biometric risks, or
alternatively to guarantee a given investment perIormance or level oI beneIits.
Pichardo-Allison (2009)
1
provides an example oI the use oI such security mechanisms in
Sweden, where a series oI buIIers named AP Iunds where set up at the turn oI the
millenium to protect public company pensions. The pension system is set up as a PAYG
structure with incoming contributions used to pay the beneIits oI current retirees, whilst
the AP Iunds are used as buIIers to cover Iuture contributions.
A number oI Member States allow IORP`s to partially Iinance solvency buIIers via
subordinated loans` which are in turn Iacilitated through recovery periods. A subordinated
loan is ranked behind the rights oI members and beneIiciaries in terms oI the legal
obligations oI repayment. The liability oI such loans may be written to another party other than
the sponsoring company e.g. an insurance company, and thus oIIer unlimited loss absorption in
case oI an insolvency situation as all payments on the loan are subordinated to all
pension liabilities. In countries where the IORP does not itselI bear biometric risks, but where
the IORP has Iull recourse to the sponsor, such buIIers are not required.
TabIe 7.3 Summary overview of security mechanisms
Source: CEIOPS 2008
7. Ex post security mechanisms - sponsor commitment` and guarantee funds`
In some countries ex post security mechanisms are in place in the event oI an IORP being Iaced
1
Pichardo-Allison, R. (2009, April 15). Swedish AP system put to the test. Global Pensions. Retrieved Irom
http://globalpensions.com/.html?pagegpdisplaynews&tempPageId852657
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with an underIunding crisis. Countries with such buIIers include the UK, Ireland, Germany,
Belgium and Luxembourg. In this group the sponsoring undertaking is the driving Iorce behind
the provision oI beneIits Ior the employees and thereIore plays a key role in the Iunding oI the
IORP. The role played by the sponsor in relation to the pension commitment will depend
largely on the nature oI the promise in the context oI the national legislation oI the country in
question.
In some countries, payment oI Iuture contributions by the sponsor may be adjusted upwards to
eliminate under Iunding, whereas in others contribution levels can be renegotiated by the
parties involved with a view to generating a recovery plan to cover shortIalls in Iunding.
However, schemes operating cross-border are obliged to be Iully Iunded` at all times. The
actual length oI the recovery period Ior all countries depends on the IORP`s individual
circumstances and risk proIile.
A number oI Member States, including the UK, use guarantee Iunds` as a security
mechanism in the event oI the sponsor or the IORP becoming insolvent. This acts as a levy
on the sector to cover insurance providers against the risk that they will have to bail out
sponsors in the Iuture. Contributions to the guarantee Iund are made by both national
governments and Iees Irom IORP`s and their sponsors. The Iund is designed to act as a
mechanism oI last resort` in the event oI there being no Iurther recourse to a sponsor, or iI
the assets oI the IORP are insuIIicient to pay out the beneIits due. Pension guarantee
schemes help to maintain solvency levels and therein the security oI member`s retirement
plans. Such Iunds however run the risk oI creating moral hazard` Ior the pensions industry
in that they act as a saIety net Ior the poor risk management or governance oI Iunds.
8. Reduction of accrued pension rights and non-mandatory increases
In extenuating circumstances, renegotiation with the IORP, unions, and sponsors may include a
reduction oI accrued pension rights in order to restore a situation oI under Iunding. A situation
such as this would arise as a result oI Iailed risk management or supervision and would be
exercised with a view to saving the IORP Irom insolvency.
CEIOPS (2008)
1
reports that in countries where Iuture indexation is conditional and
thereIore not explicitly reserved Ior, indexation may be granted on a year-by-year basis
depending on the IORPs` current Iinancial position and prospects thereoI. Reduction oI
these non-mandatory increases can in some countries serve as a security mechanism. By not
Iully granting indexation, the IORP reduces the chance oI insolvency; the money that would
otherwise have been applied to indexation is thus used to strengthen the Iunding ratio as part oI
a broad recovery plan.
1
CEIOPS (Ed.). (2008, April). Survev on Fullv Funded, Technical Provisions and Securitv Mechanisms in the European Occupational
Pension Sector. Retrieved Irom
http://www.ceiops.eu/media/docman/publicIiles/publications/submissionstotheec/ReportonFundSecMech.pdI
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} The need for assessment
Lommen (2008)
1
comments that comparing the prudential regimes oI IORPs in diIIerent
European countries is like comparing apples with pears in that a Iramework or benchmark Ior
the assessment oI the combined eIIectiveness oI all individual mechanisms is currently lacking.
In Belgium past cases oI insolvency were usually resolved by means oI additional
sponsor contributions. In Germany, a combination oI available capital, increased contributions
and beneIit reduction was used to tackle the problems arising Irom the Iinancial crisis in the
beginning oI this century. In The Netherlands a combination oI high solvency buIIers,
increased contributions, reduction oI indexation and the use oI subordinated loans successIully
absorbed these problems.
CEIOPS highlights that technical provisions and supplementary security mechanisms
Irequently counterbalance each other. In countries where technical provisions are set
prudently, the need to Iinance supplementary security mechanisms is oIten minimised.
Elsewhere, the opposite is true. It is also important to consider the accountancy standards
applicable to IORPs and sponsors when determining solvency rules that protect the security
oI schemes.
Instruments providing ex post security such as sponsor contributions are usually needed in
times oI economic downturn, however such Iinancial obligations may threaten the economic
health oI the sponsor and therein present itselI as a credit risk to the individual member. This
impact can be mitigated by the existence oI additional Iunds or assets as collateral on
which a claim may be made by the IORP and also by allowing a longer recovery
period that spreads out the eIIects oI adjustment measures over the cycle.
1. Ranking
In order to prevent insolvency or to recover Irom actual insolvency, security
mechanisms may operate simultaneously or sequentially; in the latter case, one security
mechanism takes over when the previous one is exhausted (CEIPOS 2008)
2
. Mechanisms, such
as solvency buIIers, subordinated loans or a guarantee Iund, are capitalised, which means that
security is arranged up-Iront. Those against the use oI capitalized security Ior covering risk
would argue that this approach ties ups capital ineIIiciently and increases the upIront cost to
employers and hence may interIere in the balance between cost and pension provision
where employer sponsorship is entirely voluntary.
CEIOPS commented on the impact oI the Iinancial turmoil on IORP`s as institutional investors
in its Spring Financial Stability Report (2009)
3
with speciIic reIerence to the Iinancial
1
Lommen, J. (Ed.). (2008). IORP II. towards a new solvencv framework? Retrieved Irom
http://www.ipe.com//IItowardsanewsolvencyIramework28781.php?articlepage1
2
CEIOPS (Ed.). (2008, April). Survev on Fullv Funded, Technical Provisions and Securitv Mechanisms in the European Occupational
Pension Sector. Retrieved Irom
http://www.ceiops.eu/media/docman/publicIiles/publications/submissionstotheec/ReportonFundSecMech.pdI
3
CEIOPS. (2009, June). Spring Financial Stabilitv Report. Retrieved Irom http://www.ceiops.eu/////Spring-Financial-Stability-Report-
2009.pdI
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conditions and Iinancial stability oI the insurance and occupational Iund sector in the EU/EEA.
The report noted that although IORPs had suIIered as a result oI sharp drops in equity markets,
the impact "had not been as severe as seen in other Iinancial sectors as the long-term nature oI
the liabilities aIIords some protection in this respect and IORPs have not experienced the
liquidity problems experienced elsewhere". However, CEIOPS did recognize that the DB
occupational pension Iund sector is under increased pressure because oI low interest rates and
prevailing longevity risk. The report revealed that the Iinancial crisis had taken its toll on the
Iunding levels Ior DB schemes across Europe with countries such as the Netherlands and the
UK reporting Iunding levels oI less than100.
CEIOPS counselled that: "it is essential that IORPs do not over-react in the Iace oI the
downturn; moreover they should ensure that they are active and alert to potential changes in
the Iunding level oI the IORP and also the health oI the sponsor". It noted that closer
scrutiny by supervisors was becoming more oI a common Ieature, and added that "the
current regime is seen by many as being Ilexible enough to cope".
2. The development of IORP`s in Europe
A key concern oI IORP critics is on the issue oI whether they are the most eIIective and cost
eIIicient vehicles Ior the provision oI occupational pensions. On the one hand there is the
prevailing argument that the strict regulatory regime governing IORP`s results in capital
being tied up unnecessarily that could otherwise be invested in the marketplace; supporters
oI IORP`s however would propose that the same strict governance structures could help
develop adequate and low-cost workplace pension provision that avoid incentives Ior
excessive risk-taking in managing investments.
CEIOPS has taken an active role in identiIying those European pension schemes which are
not currently covered by any European Union legislation, as part oI its continuing review oI
cross-border pension supervision. Henderson (2009)
1
reports that in a recent study
conducted by CEIOPS between June 2008 and June 2009, it was revealed that 10 new cross-
border IORPs had been created, thus bringing the total number oI IORPs in existence to 80.
Ireland, Liechtenstein, Luxembourg and the UK all reported new IORP activity over the
year, while Finland and Portugal announced that activity had ceased. Hungary and Romania
became two new European countries presenting their territories as host states Ior IORP`s,
whereas Slovenia removed itselI as a host territory.
The total IORP Iigure was however reduced to 76 when the regulatory authorities oI Austria,
Finland, Luxembourg and Portugal announced that they had experienced IORP withdrawals
during the same period. The Iour withdrawals suggested that there are ongoing disputes over
what exactly constitutes the technical provisions Ior employers that wish to put in place cross
border schemes. OI greater signiIicance, was the revelation by CEIOPS in the report that
there was evidence oI a clear trend developing in the most recently established IORP`s Ior DC
based arrangements with up to 350 members.
1
Henderson, J. (Ed.). (2009, November 9). Slow IORP growth highlights cross-border complexitv. Retrieved Irom http://www.ipe.com//iorp-
growth-highlights-cross-border-complexity33215.php
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Chapter 8 Occupational pensions and the Solvency II draft Directive
Both occupational pension Iunds and liIe insurers IulIil the role oI pension providers across the
EU. A broad spectrum oI pension Iund arrangements now exists with pension Iunds in several
Member States oIIering the same products as insurance companies.
In competition with the IORP Directive is the European Union Solvency II Directive with its
Iocus on risk based Iunding requirements Ior insurance companies. The DraIt Directive covers
the EEA including Norway, Lichtenstein and Iceland, as well as the 27 countries oI the
European Union. The Solvency II project aims to establish a single set oI rules governing
insurer creditworthiness and risk management. These rules will include public risk disclosure
with a view to increasing risk transparency and enIorcing market discipline on undertakings. As
a result oI transparency, the insurance industry will be able to provide greater consumer
conIidence, thus enabling stakeholders to make comparisons as to which undertakings oIIer the
most cost-eIIective protection and the more innovative and competitive products.
A} The 8o|vency || 0|rect|ve
Solvency capital requirements Ior EU insurers have been in place since the 1970s. Following a
review required by the third generation Insurance Directives oI the 1990s, limited reIorms
known as Solvency I, were agreed by the European Parliament and the European Council in
2002.
The Solvency II Directive was published on the 10th July 2007; it merges together a number oI
existing directives covering insurance and re-insurance, and incorporates changes to upgrade
the prudential supervision oI insurance. The key aims oI the Directive are to:
Deepen the integration oI the EU insurance market;
Enhance the protection oI policyholders and beneIiciaries;
Ensure that that the quantitative Iunding requirements better reIlect the true risk oI an
insurance undertaking;
Improve the international competitiveness oI EU insurers and reinsurers;
Promote better regulation;
Overcome inadequacies oI the Solvency I Directive.
1. Success factors in the insurance industry
The key to a healthy insurance industry is not solely about the technical calculation oI capital
reserves, but moreover about the approach to enterprise risk management (ERM). Under
Solvency II insurers are thus obliged to install improved governance and risk management
Iunctions and policies in order to maintain an adequate solvency position. A Iurther aim oI
Solvency II is to coerce Iinancial Iirms into retaining large capital buIIers that will oIIer
protection Irom any Iuture credit squeeze. Success will be achieved by:
Harmonising Solvency II rules across Member States;
Aligning capital requirements to each company`s risk proIile;
Emphasis on ERM;
Establishing an integrated risk-based approach to supervision.
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2. Key features
Solvency II is committed to a market consistent approach Ior the valuation oI assets, liabilities
and capital requirements. The Directive stipulates that solvency capital calculations, whether
based on an industry standard Iormula or an internal model, should be aligned to the individual
risk proIile oI the undertaking. The standard Iormula categorises risks into modules Ior capital
purposes with an allowance Ior aggregation and diversiIication across the modules. An internal
model would thus reIlect a Iirm`s speciIic risk proIile and management approach more
precisely.
3. Timeline
The draIt Directive was conceived in 2005 and is due to be implemented by Member States in
2012. Below is a timeline Ior the implementation process:
Diagram 8.1: SoIvency II timeIine
Source: EMB 2008
4. The regulatory framework - 3 Pillars
The Directive aligns the risk quantiIication and management oI insurance groups with a
Iramework Ior supervisory review and public disclosure. The objective is to provide the
industry with the necessary regulations and tools to protect pension Iund members. Solvency II
thus oIIers a complementary 3 pillar approach to saIeguard against risk. These pillars are not to
be conIused with the three-pillar variant oI EU national pension structures as outlined by the
World Bank in 1998 and covered in Chapter 1.
Diagram 8.2: Three piIIar approach to safeguard insurance-based pension schemes against risk
Source: EMB 2008
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Diagram 8.2 displays the required structure Ior an integrated risk and capital management
Iramework under the Solvency II Directive (EMB 2009)
1
. The pillars` objectives are as
Iollows:
Pillar 1
Sets minimum capital requirements;
Requires each Iirm to calculate its capital requirement using either a standard Iormula
or an internal model.
Pillar 1 involves a quantitative assessment oI risk, applying an economic risk-based approach
wherein all risks are explicitly allowed Ior. The aim is to Iacilitate the early detection oI new
and emerging risks and thereIore create greater scope Ior preventative action to be taken.
Pillar 2
Requires each Iirm to assess and manage the risks to which they are exposed and to
maintain adequate capital levels;
The Iirm's assessment oI its capital needs and oI its risks are subject to supervisory
review.
Pillar 2 takes a qualitative approach to risk assessment in terms oI internal risk management
processes and controls.
Pillar 3
Requires regulated Iirms to disclose key inIormation in their Iinancial reports;
Aims to enhance market discipline on the regulated Iirm.
Pillar 3 Iocuses on the issue oI transparency using supervisory regulation and public disclosure
requirements to encourage best practice.
B) Governance of insurance-based pension schemes
Plantin, and Rochet (2007)
2
in their study oI the prudential regulation oI the insurance industry
recognized that the cause oI Iailure Ior a number oI EU insurers was linked to poor internal
controls and risk-management processes rather than inadequate capitalisation per se. They
argued that the key issue that needed to be addressed by the insurance sector was one oI
corporate governance.
1
EMB Worlwide. (n.d.).(2009). Solvencv II - Understanding the Directive |Brochure|. Retrieved Irom
http://www.emb.com/////20II20BrochureFINAL-low20res.pdI
2
Plantin, G., & Rochet, J.-C. (2007). When insurers go bust. An economic analvsis of the role and design of prudential regulation. Princeton:
University Press.
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A primary objective oI Solvency II was to cover any blind spots` in previous insurance
industry legislation by requiring Iirms to meet regulatory principles rather than rules. The
proposed regime acknowledges that some types oI risk are best addressed through good
governance rather than by simply allocating additional solvency capital. To this end the
directive introduces a set oI qualitative requirements to control investment management in the
Iorm oI the prudent person` approach.
However, the Directive purports that the onus should be on the Iirm to demonstrate that its
governance and risk management policies are both sound and appropriate Ior its speciIic risk
proIile. To this end the supervisor requires that undertakings provide documentation oI:
policies and procedures;
roles and responsibilities;
reporting and Management InIormation (MI).
In terms oI ERM, Solvency II stipulates that the risk management Iunction should be conducted
on a continuous basis in the Iirm and include strategies, processes and reporting procedures that
cover the Iollowing:
underwriting and reserving;
asset - liability management;
investment, in particular derivatives and similar commitments;
liquidity and concentration risk management;
reinsurance and other risk mitigation techniques.
As an alternative to applying a standard Iormula Ior the calculation oI its solvency capital
requirements, insurance groups may use an internal model, provided that they can demonstrate
to the supervisor that the necessary solvency precautions have been embedded in the risk
management system. Additional responsibilities in relation to the use oI an internal model
would include documentation on the Iollowing:
design and implementation;
testing and validation;
documentation including maintenance;
analysis and reporting on its perIormance;
model improvement and enhancement.
1. Supervisory review process (SRP)
It is the job oI the supervisor to review and evaluate the compliance oI the Iirm in terms oI risk
management procedures in relation to its operating environment. The task oI an SRP is to
measure the capability oI the Iirm`s governance system in identiIying, assessing and managing
the risks and potential risks it Iaces as a business and to gauge the ability oI the company to
absorb adverse conditions in the event oI a downturn in the economy. The supervisor has the
power to Iorce Iirms to remedy any apparent weaknesses and deIiciencies in the ERM system,
including strategies, processes and reporting procedures, so as to increase conIidence in the
overall solvency position.
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The review will consider:
the system oI governance and risk assessment;
the technical provisions;
the capital requirements;
the investment rules;
the quality and quantity oI own Iunds;
the use oI a Iull or partial internal model, iI deployed.
In certain circumstance the SRP may impose a capital add-on iI the supervisor is oI the opinion
that the risk proIile oI the Iirm deviates signiIicantly Irom the assumptions underlying the
solvency capital calculation, or alternatively that there are concerns regarding the governance
standards within the Iirm. The supervisor may also request that the Iirm develop a Iull or partial
internal model iI it transpires that the standard Iormula does not accurately capture their
speciIic risk proIile.
2. Report on solvency and financial position
In accordance with the principle oI proportionality, the scope and level oI detail in public risk
disclosure should depend on the nature, scale and complexity oI the undertaking`s business.
The ChieI Risk OIIicer Forum (CRO Forum)
1
in November 2008 recommended Iive key
principles Ior risk disclosure:
Adopting the consolidated group position as the reIerence Ior public risk disclosure.
The choice between group or entity disclosure should be based on where the risks are
principally managed and overseen; group-level disclosures should thereIore be required
Ior governance as well as Ior risk and capital inIormation.
The disclosure should seek to leverage the undertaking`s existing and Iuture
International Financial Reporting Standards (IFRS) annual reporting requirements and
timing as Iar as possible.
Risks that are material should be publicly disclosed. A risk is considered material iI its
omission or misstatement could inIluence the economic decisions oI users taken on the
basis oI the public disclosure, or iI the undertaking considers them large enough to
threaten its operations.
The disclosure should be relevant and appropriate to both the risks involved and the
needs oI the relevant audience (i.e. inIormed knowledgeable users`).
For the purposes oI comparison between undertakings, capital requirements should be
disclosed at the conIidence level and holding period assumed in the Solvency II
standard Iormula (using the standard model or an equivalently calibrated internal
model).
1
CRO Forum (Ed.). (2008, November). Public risk disclosure under Solvencv II. Retrieved Irom http://www.croIorum.org/publications.ecp
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6} R|sk management funct|on of |nsurance-based pens|on schemes
The risk management Iunction is responsible Ior the control oI risks across the organization and
is divided into risk categories, with dedicated departments Ior non-liIe underwriting risk, liIe
and health underwriting risk, market risk, credit risk and operational risk. At the business level,
risk managers oI each oI these departments identiIy, assess and manage Iinancial and non-
Iinancial risks, and report to the local Risk Director who in turn reports to the ChieI Risk
OIIicer. None oI these departments is actually involved in the execution oI business. Instead,
they independently oversee risk-taking activities, and set the risk management guidelines and
best practice standards that the business units implement (CRO Forum, Nov 2008)
1
.
The Solvency II Directive requires undertakings to produce a report on their solvency and
Iinancial position which includes the Iollowing:
1. A risk overview and governance framework
This risk overview and governance Iramework outlines the control procedures and monitoring
systems involved in the risk management decisions oI the undertaking. These will include a
description oI roles and responsibilities oI Board oI Directors and risk management committee
members with a view to ensuring that the holders oI key risk management positions are Iit and
proper persons in accordance with the required criteria. The CRO Forum recognizes that the
Iramework will also include inIormation on outsourcing agreements which transIer key risk
management Iunctions and related activities to external parties outside the undertaking and its
subsidiaries.
The primary objective oI the risk management process is to limit the impact oI adverse events,
while ensuring an eIIicient use oI capital to support business activities and create value. The
risk control Iramework is thus responsible Ior the protection oI the Iinancial strength oI the
undertaking, protection oI reputation, risk transparency, management accountability and
independent oversight.
The overview will require descriptions oI the Iollowing:
Risk policy and control Iramework;
Risk reporting activities and who is the target audience;
List oI material risk` areas that the undertaking is exposed to and the classiIication oI
material risk areas in terms oI being assessed quantitatively or qualitatively;
Risk and solvency assessment either using the standard model` speciIied by Solvency
II regulation or alternatively a description oI the internal model` providing inIormation
with regards the main diIIerences between the standard Iormula and the internal model
used by the undertaking Ior the calculation oI its Solvency Capital Requirement (SCR);
Description oI risk mitigation activities (incl. reinsurance, Iinancial market
instruments).
1
CRO Forum (Ed.). (2008, November). Public risk disclosure under Solvencv II. Retrieved Irom http://www.croIorum.org/publications.ecp
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2. Risk assessment by risk category
An assessment oI material risks is made by the businesses, and challenged, reviewed and
aggregated at group level by the Group`s risk department. This process would include both
quantitative and qualitative assessed risks in terms oI required risk capital. It is necessary to
have an outline oI policies, processes and standards in place to manage the Iollowing:
Non-liIe underwriting risk;
LiIe and health underwriting risk;
LiIe and health underwriting risk;
Market risk;
Credit risk;
Operational risk.
a) Non-life underwriting risk
Non-liIe underwriting risk is the risk arising Irom the underwriting oI non-liIe insurance
contracts. It includes the risk oI loss or oI adverse change in the value oI insurance liabilities
resulting Irom non-liIe premium and reserve risk, as well as non-liIe catastrophe risk.
b) Life and health underwriting risk
LiIe and health underwriting risk is the risk arising Irom the underwriting oI liIe and health
insurance contracts. It includes the risk oI loss or oI adverse change in the value oI insurance
liabilities resulting Irom mortality risk, longevity risk, disability and morbidity risk, liIe
expense risk, revision risk, lapse risk, liIe catastrophe risk, health expense risk, health premium
and reserve risk, and health epidemic risk.
c) Market risk
Market risk is the risk oI loss or adverse changes in the Iinancial situation, caused by
Iluctuations in the level and the volatility oI the market prices oI assets, liabilities and Iinancial
instruments. This comprises interest rate risk, equity risk, real estate risk, currency risk, credit
spread risk. Market risk arises Irom three main sources: the Group`s investment activities, the
Iinancial market sensitivity oI the economic value oI liabilities, and the capital markets trading
activities.
Stress tests should be used to estimate the potential loss oI the investment portIolio under
extreme market conditions. These would be conducted using parameters such as an estimated
20 Iall in equity, real estate and hedge Iunds, or alternatively an interest rate rise oI 100bp in
all currencies, in order to Iorecast the impact oI rare occurrences on the economic balance
sheet.
d) Credit risk
Credit risk is the risk oI loss or adverse change in the Iinancial situation, resulting Irom
Iluctuations in the credit standing oI issuers oI securities, counterparties and debtors to which
the undertaking is exposed. The credit standing oI insurers is reIlected in the ratings oI the
bonds that they hold in their portIolio. Meanwhile, credit risk exposure arises Irom Iinancial
transactions with asset issuers, debtors, intermediaries, policyholders or reinsurers; it is
comprised oI credit deIault risk and credit migration risk.
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e) Operational risk
Operational risk is the risk oI loss Irom inadequate or Iailed internal processes, Irom personnel
and systems, or Irom external events including legal risk.
It is important that risks are assessed qualitatively along with an examination oI the policies,
processes and standards that are in place to manage the Iollowing:
Liquidity risk;
Strategic risk;
Reputational risk.
f) Liquidity risk
Liquidity risk is the risk that the company does not have suIIicient Iunding available to meet its
Iinancial obligations when they Iall due or the risk oI not being able to borrow Iunds in the
market at an acceptable price to Iund its commitments.
g) Strategic risk
Strategic risk is the risk oI any current or prospective impact on earnings, or capital arising
Irom adverse business decisions. Strategic risk can also be as a result oI the improper
implementation oI decisions or lack oI responsiveness to industry changes.
h) Reputational risk
Reputational risk is the risk oI potential damage to the organization Irom the deterioration oI its
reputation or standing due to a negative perception oI its image among customers,
counterparties, shareholders or regulatory authorities.
0} R|sk m|t|gat|ng act|v|t|es
An undertaking would mitigate part oI its risks in order to limit catastrophe exposure and
reduce the impact oI a potential reduction in asset values or a potential increase in liability
values caused by unIavourable market movements. Reinsurance would be used to protect
against catastrophic claims, to diversiIy risk, to stabilise Iinancial ratios and to obtain additional
underwriting capacity. In addition, capital market instruments may be used to protect against
insurance and Iinancial market losses.
Capital adequacy management
As part oI the new culture oI transparency, insurance groups are required to disclose their
objectives, policies and processes Ior managing the capital and/or solvency position. An
undertaking should develop a policy oI maintaining a strong capital base in order to support the
development oI its business and to be adequately capitalised at all times. The onus is on the
operation to have such measures in place even Iollowing a signiIicant adverse event. The
requirement includes submission oI both qualitative and quantitative inIormation on the
undertakings position with regards:
Internal capital adequacy;
Regulatory solvency issues.
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The internal risk capital model plays a signiIicant role in solvency management and capital
allocation. The Solvency II Directive requires that an undertaking should develop models such
as the value-based approach` to measure and manage its business activities and to optimise
capital allocation. The internal available capital may be based on published shareholders`
equity adjusted to reIlect the Iull economic capital base available to absorb any unexpected
volatility in results oI operations. This shareholders` equity Iigure may include the present
value oI Iuture proIits in the liIe assurance and pensions segment.
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Chapter 9 Solvency II and quantitative funding requirements
'You onlv learn who has been swimming naked when the tide goes out` (Warren Buffett 2009)
The Solvency II Directive outlined a series oI quantitative yardsticks Ior the calculation oI
Iunding requirements Ior insurance operations. In order to evaluate the impact oI these Iunding
requirements, a number oI Quantitative Impact Studies (QIS) were perIormed by CEIOPS in
2007 called the QIS 3 Iramework
1
, which summarized the current status oI the standard model
Ior insurance companies.
0|8 3 framework
The QIS 3 model consists oI two building blocks:
A market consistent valuation oI pension liabilities, reIerred to as Technical
provisions`;
Calculation oI the Solvency Capital Requirement (SCR).
Diagram 9.1: Overview of QIS 3 modeI
Source: CEIOPS 2007
1. Technical provisions (TP)
The QIS 3 model highlighted above requires a market consistent valuation oI assets and
liabilities using a total balance sheet approach. In terms oI assets, market values are normally
ascertained using a mark-to-market` approach at a given point in time, or alternatively can be
calculated on a mark-to-model` basis wherein values are based on internal assumptions or
Iinancial models. However, as pension liabilities are non-hedgeable due to the nature oI
embedded longevity risk, it is invariably diIIicult to value them. The valuation oI pension
liabilities is thus split into two parts, the best estimate oI liabilities` (BEL) and the risk
1
CEIOPS (Ed.). (2007). QIS Technical Specifications Part I Instructions. Retrieved Irom
http://www.ceiops.eu//////TechnicalSpeciIicationsPart1.PDF
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margin`.
CEIOPS (2007)
1
calculated the BEL as being equal to the expected present value oI all
potential cash Ilows arising Irom the pension promises calculated according to the Iollowing
principles:
Valuation based on already accrued beneIits;
Realistic assumptions including Iuture expenses;
Risk Iree discounting based on the swap curve`;
Allowance Ior market value oI options and guarantees; the BEL has to include both
guaranteed beneIits and extra beneIits such as Iuture conditional indexation.
The technical provisions must also include a risk margin that meets the objectives either to
transIer the portIolio to a third party, or to recapitalize the pension Iund to ensure a proper run-
oII by the original undertaking. Underlying assumptions can be summarized as Iollows:
Assume that the pension Iund becomes insolvent at the end oI the Iirst year due to
economic loss and that the portIolio oI assets and liabilities is taken over by another
pension Iund (the reIerence pension Iund).
The reIerence pension Iund has to be compensated Ior additional SCR that it has to put
up during the whole run-oII oI the portIolio.
Assume that the reIerence pension Iund would eliminate investment risk (resulting in
zero SCR Ior market risks Irom year 2 onwards; only liIe underwriting and operational
risk remain).
The risk margin is equal to the present value oI the cost oI Iuture SCR that the reIerence
pension Iund will have to put up during the run-oII oI the portIolio oI assets and liabilities Ior
the in-Iorce book oI business at the end oI next year (t1).
The TP equals the sum oI BEL and the risk margin. The diIIerence between the market value oI
the assets and the TP gives the available capital` that can be used to absorb risks.
Although the QIS 3 Iramework was initially designed Ior (liIe) insurance companies, the model
can be extended in order to better reIlect the speciIics oI pension Iunds. A study was conducted
by Peek et al (2008)
2
on the evaluation oI the impact oI risk based Iunding requirements on
pension Iunds. This was conducted by perIorming quantitative analyses oI Iunding
requirements based on the Solvency II (QIS 3 methodology) risk based valuation Iramework.
The results suggested that as the underlying principles Ior risk based Iunding requirements are
similar Ior both the IORP and Solvency II approaches to pension management, that there may
well be scope to modiIy the QIS 3 in order to create a more level playing Iield` Ior the
pensions industry as a whole.
1
CEIOPS (Ed.). (2007). QIS Technical Specifications Part I Instructions. Retrieved Irom
http://www.ceiops.eu//////TechnicalSpeciIicationsPart1.PDF
2
Peek, J, Reuss, A, & Scheuenstuhl, G (Eds.). (2008, March). 'Evaluating the Impact of Risk Based Funding Requirements on Pension
Funds`, OECD Working Papers on Insurance and Private Pensions No 16. Retrieved Irom OECD Publishing. website:
http://www.oecd.org/dataoecd///.pdI
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2. Solvency II and regulatory capital requirements
The European Commission adopted the Solvency II proposal as a more risk oriented instrument
in 2005. The model was reviewed in July 2007 and an amended proposal issued on 26 February
2008. The Solvency II Framework Directive proposes two regulatory capital requirements, the
solvency capital requirement (SCR) and the minimum capital requirement (MCR).
a) Solvency Capital Requirement (SCR)
The Solvency Capital Requirement (SCR) has been established as the new standard Ior
insurance-related operations to calculate their solvency positions annually. Available solvency
capital is deIined as the market value oI the assets minus market value oI the liabilities. The
undertaking`s SCR must thus be covered by an equivalent amount oI assets in excess oI
liabilities. II the SCR is not covered then the Iirm must submit a recovery plan to the supervisor
and will be closely monitored to ensure compliance with this plan.
The SCR is calculated in one oI two ways:
use oI the standard Iormula;
use oI an internal or partial internal model.
The standard SCR Iormula is a risk-sensitive consideration oI all aspects oI the Iirms` business,
including the duration oI liabilities, the assets held, and any operational risk.
The SCR calculation is based on the Iollowing principles11:
The SCR should deliver a level oI capital that enables an insurance undertaking to
absorb signiIicant unIoreseen losses and gives reasonable assurance to policyholders
(plan members) that payments will be made as they Iall due;
It should reIlect the amount oI capital required to meet all obligations over a speciIied
time horizon (1 year) to a deIined conIidence level (99.5);
In doing so, the SCR should limit the risk that the level oI available capital deteriorates
to an unacceptable level at any time during the speciIied time horizon.
The SCR should take into account all signiIicant, quantiIiable risks (including market
risks, liIe underwriting risks and operational risk).
In the QIS 3 Iramework, capital requirements are Iirst calculated separately Ior each individual
type oI risk assuming a worst-case change in the underlying risk Iactor e.g. a signiIicant drop oI
over 25 in the index Ior global equity investments. The capital requirements Ior the diIIerent
risk Iactors are then aggregated using predeIined correlation matrices employing a variance-
covariance approach.
b) Internal models for solvency capital requirements
Subject to approval by the supervisor, a Iirm may replace the standard Iormula SCR parameters
by an internal model. The internal model allows a much more bespoke risk assessment oI a
particular business, and has the potential to be a useIul management tool.
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To achieve supervisory approval a Iirm must demonstrate that it`s capital adequacy model has
passed various stress tests` and sensitivity analyses and is thus capable oI being calibrated to
the regulatory one-year 99.5` VaR level as speciIied in the SCR.
Firms will thereIore need to justiIy the assumptions underlying their model. They may take into
account Iuture management actions that they would reasonably expect to carry out in speciIic
circumstances, as long as the model makes allowance Ior the time necessary to implement such
actions. The model should be thoroughly documented, including an outline oI the model design
and details oI the methodology, data and assumptions used. Any major changes to the previous
version oI a model should also be documented.
Whilst the calculation oI assets and liabilities and the SCR can be determined either by an
approved internal model or by a standard approach, it is envisaged that the standard approach
would present more oI an approximation as it is more conservative in its valuation. Supervisors
may require Iirms to run their internal model on relevant benchmark portIolios and use
assumptions based on external, rather than internal, data in order to demonstrate that the
resulting capital requirements are appropriate. Some Iirms may be required to develop a Iull or
partial internal model iI the supervisor considers that their risk proIile deviates signiIicantly
Irom that assumed Ior the standard Iormula SCR.
c) Minimum Capital Requirement for Solvency II Framework
The MCR is the level oI capital below which policyholders are deemed to be exposed to an
unacceptable level oI risk and at which there is supervisory intervention. The calculation oI the
MCR is being considered at an 80 VaR conIidence level over a one year horizon.
There has been considerable diIIerence oI opinion among stakeholders on the methodology Ior
calculating the MCR. The Committee oI the European Assurance (CEA) argued that Iailure to
adopt a risk-based approach to the calculation oI the MCR in the proposed Solvency II
Framework Directive would perpetuate the disadvantages oI the current regulatory system
(CEA April 2008)
1
. They advocated that the MCR should be appropriately linked to the SCR so
that both reIlect the true risk proIile oI the insurer.
The CEA proposed a solution wherein the MCR oI a solo` operation is calculated annually as a
percentage oI the SCR and thereaIter reviewed and approved by the supervisor whether derived
Irom the use oI the standard Iormula or internal model. In conjunction with each calculation oI
the SCR, this percentage is then re-expressed as a percentage oI the insurer`s technical
provisions (or premiums as appropriate) to address the issues oI legal certainty and auditability
as well as to avoid any interim calculation oI the SCR. The CEA recommended a so called
compact` approach to the calculation oI the MCR which strikes a balance between risk
sensitivity and simplicity (see example below).
Example of MCR calculation
In this example, the assumption is made Ior a particular liIe company, wherein at year end the
1
CEA (Ed.). (2008, April 8). CEA position on Solvencv II and pension funds. Retrieved Irom http://www.cea.eu////position-paper.pdI
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MCR calculated as a percentage oI the SCR (MCRFactor *Approved SCR) is 30 million and
technical provisions (Ior liIe) equal to 1.000 million. The MCR is thereaIter re-expressed as 3
oI technical provisions (i.e. 30/10003). Assuming that at a Iuture date (Ior example, 31/03),
the technical provisions are 1.100 million, the MCR would be 33 million (i.e. 3 oI 1.100
million). The 3 rate would thus apply until the next point when the SCR is re-calculated with
supervisory review. At that point, the MCR is re-calculated as a percentage oI the approved
SCR and then re-expressed as a percentage oI the updated value oI the technical provisions.
The CRO Iorum (Nov 2008) acknowledged that iI the MCR is not sensitive to risk and
diversiIication or does not give due credit to risk mitigation, it may create artiIicial constraints
and act as a disincentive to the use oI internal models and good risk management`. They argue
that such an approach would allow the MCR to act sensibly as the Iinal step in an escalating
ladder oI intervention.
d) Stress tests
Stress tests are an important part oI risk disclosure embedded within the system oI governance;
they are a key tool in the decision-making processes oI the undertaking, and should be
conducted regularly to reIlect the Iirm`s risk proIile.
Instead oI conducting Iinancial projection on a "best estimate" basis, a company may opt to
conduct a stress test` in order to examine how robust their risk position would be in the event
oI unIoreseen circumstances occurring such as a stock-market crash, interest rate hikes, or aIter
the acquisition oI a big insurance portIolio.
A Iorm oI stress testing was adopted in Switzerland, known as the Swiss Solvency Test (SST)
which calibrated a level oI intervention between the MCR and SCR equivalents. The
approach was as Iollows: the supervisor characterised a number oI historical scenarios
(e.g. stock market crash 2000/01, US interest rate crisis in 1994, terrorism, pandemic) and
Iirms computed how much capital would be absorbed as a result. The results suggest that on
average about 40 oI the SST SCR would be consumed iI any oI these scenarios materialised.
The intermediate level was thus set at 60 oI the SST SCR so that on average none oI the
scenarios pushed insurers beyond the second threshold oI the MCR.
The SST uses a Marginal Cost oI Capital (MCoC) approach to MVMs. Although the CRO
Forum`s proposed MCoC approach diIIers in several respects Irom the SST approach, the
Iundamental concepts are the same and thereIore insight can be gained based on the SST
experience.
The results oI the SST Field Test have shown that MVMs, under a MCoC approach,
appropriately reIlect the underlying risk inherent in the business. The Iollowing conclusions
were made by the CRO Forum (2007)
1
.
The calculation oI the MVMs during the Iield tests were Iound to be quite stable Irom
period to period;
1
CRO Forum. (2007, October 14). Feedback on Solvencv II Draft Directive. Retrieved Irom http://www.croIorum.org/
publication/onsolvency/
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LiIe insurers writing mainly savings products tend to have relatively small MVM
since insurance risk is small compared to market risk;
LiIe insurers writing risk products have a large relative MVM since they have a large
exposure to biometric risk and a long duration oI the run-oII portIolio.
The CRO Forum argued that the SST approach could be applied in Solvency II to provide
evidence to calibrate the MCR. They advocated that CEIOPS should set out a number oI
relevant historical scenarios and undertake its own calibration study with the goal oI setting the
intervention level based on the evidence generated. Example: Suppose that on average x oI
the SCR is consumed iI any oI the stress test scenarios materialised. II the MCR equals x oI
the SCR one would expect about 50 oI the industry to breach the MCR as a result oI any oI
these events. CEIOPS and the Commission could equally test how many insurers would be
in breach oI the MCR Ior diIIerent values oI x and choose a value that avoids
generalised non-compliance with the MCR.
e) Own risk and solvency assessment (ORSA)
Each Iirm is obliged to conduct its own risk and solvency assessment` (ORSA), based on its
risk proIile, risk appetite and business strategy. ThereaIter the results are submitted to the
supervisor as part oI the supervisory review process
The ORSA acts as an internal control procedure used to monitor and manage risk and
highlights areas where the Iirm believes the assessment deviates Irom the assumptions
underlying the SCR calculation. The submission must include details oI the methods used and,
in cases where an internal model has been deployed, a recalibration that transIorms the internal
results so that they are consistent with the SCR calculations.
Risk management processes are required Ior the identiIication and quantiIication oI risk in a
coherent Iramework. These processes must be suIIiciently streamlined so there is no undue
delay in updating the assessment Iollowing any signiIicant change in the business risk proIile.
Firms must also demonstrate that this assessment has an inIluence on strategic decision making
and is not just a box-ticking` technical exercise.
The ORSA is an attempt to Iormalize best practice` in the insurance industry. The aim is to
ensure consistency between models used Ior internal management and Ior regulatory reporting.
Firms who present a thorough ORSA are in position to gain competitive advantage by making
more inIormed business decisions.
It appears unlikely that stress tests` and ORSA alone may be suIIicient to reassure regulators
that the risk management processes oI insurance Iunds are adequate. As the global economy
continues to ebb, some oI the carnage being leIt by the larger insurance / pension Iunds is
becoming more visible. The Iear is that as the tide goes out, the Iull, gruesome eIIect on some
oI Europe`s largest pension players is yet to be exposed. It is important thereIore that a wide
range oI risk management instruments are employed to guarantee that pension obligations can
be met.
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f) Actuarial function
Firms are required to establish a strong actuarial Iunction in order to ensure a robust calculation
oI technical provisions. The actuarial Iunction will oversee the technical calculations, to make
sure that appropriate methodologies and data are used. Actuaries should also be involved with
risk modelling in terms oI calculation oI the SCR and the ORSA; in addition they are
responsible Ior underwriting policy and ensuring the adequacy oI reinsurance arrangements.
The CRO Iorum (2007)
1
argue that there should be no `prudence` included on top oI the market
value oI liabilities to cover the risk that the actual values vary over time Irom the current
market value estimates, as in the IORP Directive. They advocate that it is the purpose oI the
SCR to cover this risk and suggest that a mixed approach where some risks are considered
within the valuation oI assets or liabilities and some with the solvency requirement will
inevitably lead to inconsistencies, double counting and ultimately additional costs Ior
consumers.
g) Annual solvency and financial condition report
As part oI the public disclosure requirement under Solvency II (Pillar 3) Iirms will be required
to publish an annual report on solvency and Iinancial condition.
This report should cover:
The business in terms oI its perIormance and governance system;
A description oI risk exposure, concentration, mitigation and sensitivity by risk
category
The risk proIile and the assumptions underlying methods oI valuation Ior assets and the
technical provisions;
Details oI the capital management structure with a Iocus on the MCR and SCR;
Disclosure oI inIormation in relation to diIIerences between the standard Iormula and
any internal model used.
Much oI this material will already have been generated internally by Iirms who practise sound
risk management. However, additional checks and balances may be required by the supervisor
to ensure that the published details are both accurate and transparent.
h) Valuation of assets and liabilities
It is important that there is a market consistent valuation oI assets and liabilities. The Directive
stipulates that valuation oI assets and liabilities should be based on a total balance sheet,
market-consistent value based approach. Where the true market value is diIIicult to ascertain,
assets and liabilities should thus be valued on projected best estimate cash Ilows using market
consistent techniques.
1
CRO Forum. (2007, October 14). Feedback on Solvencv II Draft Directive. Retrieved Irom http://www.croIorum.org/
publication/onsolvency/
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i) Group supervision
Group insurance schemes will be supervised centrally on a consolidated basis that recognizes
group diversiIication beneIits so that there is one binding SCR Ior groups with a streamlined
regulatory process. As in the requirements Ior an individual Iirm, risk management, internal
control systems and reporting procedures need to be implemented and controlled on a
consistent basis at the group level. The annual solvency and Iinancial condition report may be
produced at the group level with inIormation covering both the group and subsidiaries.
The group needs to demonstrate that it has suIIicient Iunds to cover its SCR across the EC and
that there is no practical or legal restriction on the prompt transIer oI Iunds to support
subsidiary Iirms within the group. To this end the group supervisor will review annually any
signiIicant risk concentration at the level oI the group and any signiIicant intra-group
transactions.
The group-level SCR may be calculated using either the standard Iormula or an approved
internal model. The approval process Ior use oI an internal model is similar to that oI an
individual Iirm. However, should the supervisor suspect that the group model does not properly
reIlect the risk proIile oI the subsidiary, they will have the power to impose capital add-ons` to
the individual Iirm, or alternatively insist that its SCR is calculated using the standard Iormula.
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Chapter 10 The economic (solvency) balance sheet and the MCoC
In their interpretation oI the CEIOPS QIS 3 building blocks, the CRO Forum (2007)
1
advocated
a market consistent approach to risk management through the application oI an economic
balance sheet` model. The main components oI the economic balance sheet are the market
value oI assets, the market consistent value oI liabilities and the solvency capital requirement.
A} The market cons|stent approach to r|sk management
Through the consistent measurement oI assets and liabilities, the economic balance sheet
distinguishes between the underlying asset and liability values and the capital required Ior
solvency purposes. This means that capital requirements consider risks emanating Irom both
sides oI the balance sheet, with both assets and liabilities evaluated on a market value basis.
Diagram 10.1: The economic (soIvency) baIance sheet
Source: CRO forum 2007
Diagram 10.1 depicts the main components and sub-components oI the market consistent
economic balance sheet. These comprise oI:
1. The market value oI assets (MVA);
2. The market consistent value oI liabilities (MVL);
3. The Solvency capital requirement (SCR).
1
CEIOPS (Ed.). (2007). QIS Technical Specifications Part I Instructions. Retrieved Irom
http://www.ceiops.eu//////TechnicalSpeciIicationsPart1.PDF
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1. Market value of assets (MVA)
The MVA in an insurance- based pension Iund is based on the mark to market` approach to
valuing assets, with the value being calculated by the Iund daily aIter the close oI the stock
exchanges. Each day the closing market value oI all securities owned is calculated along with
cash balances; total net assets are established by subtracting any liabilities, and the result is
thereaIter divided by the total number oI shares outstanding. The number oI shares outstanding
in the Iund can vary each day depending on the number oI purchases and redemptions.
2. Market consistent value of liabilities (MVL)
The MVL is derived Irom the cost oI managing the risks underlying the business on an ongoing
basis. Market values should be used where available to value the MVL, either Ior products in
their entirety or their constituent parts. Where market values are not available, market
consistent techniques should be applied in order to determine:
The expected present value oI Iuture liability cash Ilows;
The MVM Ior non-hedgeable risks.
a) Expected present value of future cash flows and the use of the SWAP rate
The calculation oI the expected present value oI Iuture liability cash Ilows includes giving
consideration to premiums, Iees, policyholder claims, expenses and commissions. All cash
Ilows that occur with certainty are deemed as being totally risk Iree and can be replicated with
risk-Iree assets oI a similar term. The CRO Forum (2007)
1
proposed that swap rates be used in
preIerence to Treasury bills as the 'risk-Iree yield curve Ior both the best estimate liability
valuation, and the market value margin valuation. Swaps allow liIe insurers and pension Iunds
to calculate discounted interest rates used Ior annuity closeout pricing in a simple, stable and
transparent way.
In many countries the market Ior swaps is deeper, longer and more liquid than the market Ior
government bonds. As a result swap rates have evolved Irom their Ioundation as a proxy AA
curve to a near-risk Iree curve at which counterparties trade risk in the Iinancial markets. It is
now standard risk management practise to use the swap rate` Ior the valuation rate oI hedging
instruments in the Iinancial markets.
The market consistent Iramework assumes that there is no reward Ior holding
diversiIiable risk. In other words, shareholders will only require an additional return Ior the
risks they take that cannot be diversiIied away. This assumption implies that any cash Ilows
that are not risk Iree but where risk is diversiIiable, should be treated as risk Iree and hence
discounted at the swap rate.
1
CRO Forum. (2007, October 14). Feedback on Solvencv II Draft Directive. Retrieved Irom http://www.croIorum.org/
publication/onsolvency/
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b) The market value margin (MVM) for non-hedgeable risks
The MVM Ior non-hedgeable risks represents the market consistent value at which the
liabilities could be transIerred to a willing, rational, diversiIied counterparty in an arms` length
transaction under normal business conditions.
It is necessary to determine in the Iirst instance whether the risks involved are hedgeable are
not. Diagram 10.2 outlines the process Ior making the MVL calculation.
Diagram 10.2: FIowchart for determining the appropriate method for caIcuIating the MVL
Source: CRO Forum 2007
The MVL may thus be interpreted as the cost oI setting up a replicating portIolio, the price oI
which can be determined Irom observable market prices.
3. The Solvency Capital Requirement (SCR)
The purpose oI the SCR is to cover all quantiIiable risks that the Iirm might Iace. It is the value
at risk (VaR) over a one year period to a 99.5 conIidence level (or 1 in 200 years). This Iorm
oI dynamic provisioning compels insurance companies to build capital buIIers` in good times
with a view to being able to absorb any unIoreseen downturn in the market.
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} Us|ng the market cost of cap|ta| (Y6o6} approach to estab||sh the YVY for non-hedgeab|e
r|sks
The cost oI capital (CoC) is deIined as the minimum acceptable rate oI return Ior capital
investments, calculated on the basis oI a weighted average oI returns on debt and equity. This
weighting is related to the relative market value oI the portIolio oI debt and equity securities.
The cost oI capital reIlects the excess return over risk Iree rates or equity risk premium (ERP)
that the Iund would require to compensate them Ior holding capital to protect against non-
hedgeable risks. The ERP is calculated as the value oI a stock based on Iuture cash Ilows to
investors and is thus a key determinant oI the cost oI equity capital.
The cost oI equity capital Ior a Iirm 'J`, written 'R
E;J
can be derived Irom the ERP oI the
stock market using the Iollowing relationship:
R
E;J
J
x R
M
where R
M
is the long-run equity premium over the risk Iree rate R
I
, and the Iirm`s beta,
J
p x reIlects the correlation oI the Iirm`s returns with those oI the equity
market overall
where p is the correlation between segment 'J and the Iirm portIolio
1
.
The CoC in the context oI this section reIers to the capital charge on Iully diversiIied capital
held to cover non-hedgeable risks only. The CoC Ior non-hedgeable risks reIlects the excess
return over risk Iree rates that an acquiring company would require to compensate them Ior the
cost oI holding capital to run-oII the business. The CRO Forum (2006)
2
recommended that a
market cost oI capital approach (MCoC) to setting MVM`s Ior non-hedgeable risks is the most
appropriate method. In the Iirst instance it is important to make a distinction between hedgeable
and non-hedgeable risks.
(i) Hedgeable risks
A hedgeable risk is a risk which can be pooled or hedged in the Iorm oI a replicating portIolio
in order to protect against any downside eIIects Irom the market. Hedging instruments may
include derivatives that protect against a Iall in the stock market or currency Iluctuation. The
cost incurred by the insurer Ior such hedging would be reIlected in the market price oI the
derivative and associated transaction Iees
1
RutterIord, J. (1996). Measurement oI Risk and Return. In Corporate Financial Strategv (pp. 26 - 29). Walton Hall, Milton Keynes: The
Open University.
2
CRO Forum. (2006, March 17). Market cost oI capital approach to market value margins, Retrieved Irom
http://www.actuaries.org.uk/data/assets/pdIIile/0009/27396/marketcostcapital.pdI
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(ii) Non-hedgeable risks
In theory it should be possible to put a price on any Iorm oI risk. However, in order to be
reasonably sure that the price accurately represents the market value oI liabilities to which a
pension Iund is committed, it is necessary to have a deep and liquid market with a range oI
instruments and prices that match the risk.
Risks Ior which a deep and liquid market is not available are reIerred to as being non-hedgeable
in that there is no given market price Ior these types oI risks. Non-hedgeable risks include:
LiIe insurance(mortality, morbidity, persistency, expense);
P&C (catastrophe, basic losses, large losses, pricing risk);
Market (interest rate risk, volatility risk);
Credit risk.
1. The market value margin for non-hedgeable risk
To compensate an investor Ior the cost oI taking non-hedgeable risks, an explicit MVM in
addition to the expected present value oI Iuture cash Ilows is demanded. Under the MCoC
approach, the MVM is deIined as the cost oI risk, i.e. a risk margin in addition to the expected
present value oI Iuture liability cash Ilows required to manage the business on an ongoing
basis. It is estimated in terms oI the present value oI the cost oI Iuture capital requirements Ior
non-hedgeable risks over the liIe oI the policy, including those annuity payments made
thereaIter Irom reserves. The MVM is added to the best estimate liability value in order to
improve transparency and Iacilitate companies` analysis oI the risks they take.
The cost oI capital Ior non-hedgeable risks thus reIlects the excess return over risk Iree rates
that an acquiring company would require to compensate them Ior the cost oI holding capital to
run-oII the business.
The MCoC approach attempts to garner a market consensus Ior the risk margin making it much
easier Ior regulators and supervisors to comprehend and manage. The CRO Forum (2006)
1
oIIer`s the Iollowing reasons Ior using the MCoC approach:
It supports appropriate risk management actions;
It provides a more appropriate reIlection oI risk, both in terms oI risk type and between
product groups;
It ensures a better response to a potential crisis in the insurance industry;
It allows Ior simpliIying assumptions, which makes this approach easy to implement;
It is transparent, easily veriIiable and understandable by the supervisor and other
constituencies;
It passes the 'use test envisioned in the Solvency II Iramework.
1
CRO Forum. (2006, March 17). Market cost of capital approach to market value margins. Retrieved Irom
http://www.actuaries.org.uk/data/assets/pdIIile/0009/27396/marketcostcapital.pdI
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2. Application of the MCoC approach to MVM`s
The MVM Ior non-hedgeable risks is calculated using the Iollowing approach:
1. Project the SCR Ior non-hedgeable risks Irom time 1 until the run-oII oI the portIolio;
2. Calculate the capital charge at each projection year (t) as the SCR multiplied by the
CoC charge, Ior non-hedgeable risks, in order to arrive at a MVM(t);
3. Discount the projected capital charge to determine the MVM.
Step 1: Project the SCR Ior non-hedgeable risks
When applying the MCoC approach, the SCR used to calculate the MVM is measured in terms
oI the VaR over a one year period to a 99.5 conIidence level (or 1 in 200 years). The MVM
is the present value oI the cost oI maintaining the SCR on a yearly basis. The SCR is thereaIter
estimated over the liIe oI the business and thus represents the change in liability value between
expected Iuture liability cash Ilows and a worst-case 99.5 percentile cash Ilow scenario.
In order to determine the MVM, the SCR Ior non-hedgeable risks must be projected Ior all
Iuture time periods i.e. Irom time 1 until the portIolio has run-oII. Using either the standard or
internal models, the solvency capital requirement Ior covering non-hedgeable risks is calculated
at time 0 Ior the projected period oI t1 to the run-oII oI the business
Step 2: Calculate the capital charge
Once capital has been projected Ior all Iuture time periods, the next step is to calculate the
capital charge at each point in time until run-oII. The capital charge Ior non-hedgeable risks can
be explicitly calculated by multiplying the Iuture SCR at each point in time by the CoC Ior
non-hedgeable risk.
Step 3: Discount the capital charge
The Iinal step in calculating the MVM is to discount the projected capital charge stream at the
risk Iree rate Ior which the swap rate is used.
3. Calculating the MCoC for pension funds
The MCoC approach can be applied to both liIe insurance business and pension Iunds. For an
existing Iund, an SCR Ior non-hedgeable risk is set up Ior the current year to support the
insured risk. In addition, an SCR will be put in place to cover the non-hedgeable reserve risks
that may occur aIter the expiration oI the contract. These would include risk that reserves may
not be suIIicient to cover pension annuity payments that have not been incorrectly estimated.
The MCoC approach applies to both the current SCR and Iuture SCR (reserve risk) and
thereIore both contribute to the determination oI a MVM. As the risk associated with pension
Iund liabilities spans over Iuture years, it is necessary to discount reserves accordingly. This is
Iurther illustrated in Diagram 10.3 below.
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Diagram 10.3: CaIcuIating the MVM for pension funds
Source: CRO forum 2006
4. The replicating portfolio
The replicating portIolio or hedge portIolio is the portIolio oI assets that most closely matches
the corresponding liability cash Ilows (see diagram below). In the absence oI arbitrage, the
market consistent value oI the liabilities should match the market value oI the replicating
portIolio.
The replicating portIolio must be set up to cover all Iuture cash Ilows other than those relating
to proIit or gains. Future cash outIlows are assessed net oI expected Iuture premium inIlows,
thus allowing Ior the expected run-oII oI policies due to claims, lapses and surrenders.
Diagram 10.4: The repIicating portfoIio
Source: CRO forum 2006
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5. Role of the SCR in times of crisis
The aim oI creating an SCR is to have a precautionary buIIer in place so that the insurance
company or pension Iund will be able to survive a stressed situation occurring and remain in
place Ior the liIe oI the business. As the situation unIolds, the insurance company may Ieel the
need to revise their expectations oI Iuture liability cash Ilows and thus recalculate the SCR and
therein MVM so that it is consistent with changes in the market environment.
Should the worst-case scenario occur, the SCR would ensure that the business was still
attractive enough to reward either a third party Ior accepting the liability or alternatively entice
new capital providers into the equation.
Recent events have demonstrated that economic theory and practise are two separate things. In
eIIect the low hanging Iruit` oI pension strategy, may not always be the most appropriate
course oI action. When a pension scheme is struggling to meet its commitments, policyholders
may opt Ior the liabilities to be taken over by an insurer that is a going concern supported by
suIIicient Iinancial resources to cover the liabilities. The key issue Ior the pension scheme in
such a buy-out` is assessing the amount oI risk that is actually being removed and in turn
calculating iI the buy-out price will exceed the expected cost oI providing the beneIits
themselves through the pension scheme. To this end the pension scheme needs to judge
whether iI adopting a similar investment strategy to that used by the insurer that it would be
able to run-oII the liabilities at a cost below the buy-out price.
The CRO Forum acknowledges that the existence oI the SCR guarantees that the insurer will be
able to survive stressed situations occurring within one year and still be in a position to meet its
obligations. It Iocuses on the market consistent value oI assets and liabilities and thereIore the
calculation ensures that all inIormation received during the year such as potential loss and also
any potential reassessment oI Iuture risk, including any potential run-oII situation in terms oI
the liabilities, is properly reIlected. In particular, the MCoC approach ensures that aIter such an
event the company will be able to appropriately remunerate either a third party accepting the
liability or new capital providers. This is achieved through the calculation oI the SCR Ior non-
hedgeable risks needed to support the liability in Iuture years and hence the MVM, which
represents a provision Ior the cost oI holding this capital.
6} we|ghted average cost of cap|ta| (wA66} approach
Investment decisions are based on the company`s cost oI capital or in terms oI the debt/equity
rate usually reIerred to as the weighted average cost oI capital (WACC). The weighted average
cost oI capital is the expected rate oI return on a portIolio oI all the Iirm`s debt and equity
securities with an adjustment Ior tax relieI on interest payments made to service the debt.
There is oIten a conIlict between the long term objectives oI a pension Iund and the pressure
Irom shareholders Ior returns in the shorter term. This may result in CFO`s working to a much
shorter time horizon than pension Iund trustees. A major Iactor in the equation oI what type oI
assets to invest in is the calculation oI the WACC. The cost oI equity capital is a key input oI
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the WACC. The cost oI equity Ior a Iirm can be derived using the Capital Asset Pricing Model
(CAPM) along with estimates oI the equity risk premium (ERP) oI the stock market as Iollows:
=
+
+ (1 - )
+
where
E: is the market capitalization
D: is the market value oI debt, and
: is the eIIective tax rate
The market or equity risk premium (ERP) is deIined as the diIIerence between the return on the
market and the interest rate on Treasury bills. When setting the ERP, the objective is to
examine historical realized returns on the stock market in excess oI the government bond yield
over an extended time period in order to ensure stability oI estimation. Over the last century,
the average market risk premium, or what additional return an investor would expect Irom
investing in the stock market rather than Treasury bills, has been 7.7 (Brealey et al, 2004)
1
.
There is a however a lot oI scope Ior argument as to what market risk premium should be going
Iorward. Dimson, Marsh and Staunton (Fall, 2003)
2
in their paper 'Global Evidence on the
Equity Risk Premium by, Journal oI Applied Corporate Finance, conducted a comprehensive
study oI equity risk premia and concluded that: 'A plausible, Iorward-looking risk premium
Ior the world`s major markets would be on the order oI 3 on a geometric mean basis, while
the corresponding arithmetic mean risk premium would be around 5.
To this end the Iigure oI 4 (average oI 3 and 5 as mentioned above) has been selected as
the cost oI equity capital (in excess oI risk Iree) in the illustration below. In addition, the Iigure
oI 2.1 is used Ior the cost oI debt (in excess oI risk Iree), based on the analyzed monthly data
oI promised yield on Aaa and Baa corporate bonds and 10-year Treasury bonds Irom February
1970 to May 2003(Lamdin (2003)
3
.
An illustrative example
The calculation assumes that a pension Iunds surplus is made up oI 80 equity capital and 20
Irom debt. A risk Iree rate oI = 4 has been selected along with an estimate Ior the cost oI
equity capital oI = 4.0 (in excess oI risk Iree). In addition, a cost oI debt capital oI =
2 (in excess oI risk Iree) and a tax rate oI 35 (adjusted Ior tax savings due to interest
1
Brealey, R. A., Myers, S. C., & Marcus, A. J. (2004). Ch 10; Introduction to Risk, Return and the Opportunity Cost oI Capital. In
Fundamentals of Corporate Finance (4th ed., p. 271). Mc Graw Hill.
2
Dimson, E., Marsh, P., & Staunton, M. (2003, Summer). Global Evidence on the Equity Risk Premium. Journal of Applied Corporate
Finance, Jol.15(No 4).
3
Lamdin, D. (2003). Corporate bond yield spreads in recent decades: an examination oI trends, changes, and stock market linkages. Business
Economics, Jol.39, Pp28-39.
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payments) are used. By applying the WACC, the resulting estimate oI the CoC Rate oI
approximately 3.2 is calculated as Iollows:
= ( + )
+
+( + )(1 - )
+
-
=
(
4.u%+ 4.u%
)
X u.8 +
(
2.1%+4.u%
)
X (1 - u.SS )X u.2 -4.u%
3.19
The calculation oI the cost oI capital allows Iund managers to generate various scenarios Ior the
return on the pension portIolio. Managers may set a target Ior the estimated long-term excess
returns versus government bonds oI between 2-4.5. In times oI increased regulation, there
will be a smaller swing in bond prices as the regulator tries to limit Iinancial and economic
risks. On the other side oI the equation, a booming economy oIten leads to low cost oI capital,
which translates into excess capacity which results in low proIits per unit oI capital and therein
depressed equity returns.
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Chapter 11 Comparison of the IORP and Solvency II models
There will always be a series oI hurdles to overcome when applying two diIIerent models to
solve a problem as complex as pension Iund management. At times such an exercise is akin to
pushing square pegs into round holes`; however there are many areas oI overlap between the
models. Ultimately the two models complement each other in that they are designed to reduce
the risk to pension Iund investors.
A} App|y|ng 0|8 3 to a 'f|na| pay' pens|on p|an
In a bid to compare the two main European pension models, Peek et al (2008)
1
analysed what
the quantitative Iunding requirements would be, iI the insurance-based Solvency II approach
(based on the QIS 3 methodology) would be applied to pension Iunds with deIined beneIit
plans. A number oI possible extensions oI the Solvency II methodology were discussed in order
to reIlect the speciIics oI DB pension Iunds. This readjusted pension model revealed that the
required Technical Provisions Ior a standard Iinal pay pension plan using the QIS 3 approach
would be 25 higher using the IAS 19 DBO (International Accounting Standard 19 DeIined
BeneIit Obligation), which covers employee deIined beneIit occupational schemes under the
accounting system oI the International Financial Reporting Standards. This valuation method
Iacilitates the projection oI unit credits based on accrued pension beneIits including an
allowance Ior Iuture salary increases. The two key reasons Ior this 25 diIIerence were as
Iollows:
The discount rate` used in the Best Estimate oI Liabilities (BEL), or expected beneIit
payments, would be calculated using the risk Iree term structure, whereas the IAS 19
DBO uses a single discount rate which is the sum oI the risk Iree yield and the AA
corporate spread (this is assumed to equate to an additional 50 basis points). This results
in lower discount rates under Solvency II and thus increases the BEL.
The IAS 19 DBO does not include a Risk Margin
In addition to the technical provisions`, the QIS 3 model requires additional capital to support
the SCR in order to cover market risk, interest rate risk and longevity risk. The end result is that
aIter allowing Ior the SCR, the Iunding level Ior this variant oI deIined beneIit pension would
be reduced to 65 (Peek et al 2008)
2
. This exercise thereIore demonstrates that the solvency
requirements could not be IulIilled Ior the generic Iinal pay plan given that Solvency II requires
all undertakings to have a minimum 100 Iunding level.
1
Peek, J, Reuss, A, & Scheuenstuhl, G (Eds.). (2008, March). 'Evaluating the Impact of Risk Based Funding Requirements on Pension
Funds`, OECD Working Papers on Insurance and Private Pensions No 16. Retrieved Irom OECD Publishing. website:
http://www.oecd.org/dataoecd///.pdI
2
Peek, J, Reuss, A, & Scheuenstuhl, G (Eds.). (2008, March). 'Evaluating the Impact of Risk Based Funding Requirements on Pension
Funds`, OECD Working Papers on Insurance and Private Pensions No 16. Retrieved Irom OECD Publishing. website:
http://www.oecd.org/dataoecd///.pdI
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The analysis argued that the SCR could be decreased by adjusting the asset allocation. The
asset allocation is an important driver oI the SCR to the extent that a reduction oI equity risk
could be achieved by reducing the equity exposure oI the portIolio. Alternatively, a better
match oI assets and liabilities would also help reduce exposure to risk.
Pension plans with risk sharing
The sharing oI risk between the sponsoring company and plan members via the contribution
policy is an important Ieature oI pension Iunds. In an underIunded situation, the plan sponsor
may be required to make additional contributions or alternatively plan members may be asked
to increase Iuture contributions. These mechanisms do not occur in the liIe insurance sector
where there seems to be no general agreement on how to best reIlect this type oI risk sharing in
a risk based Iunding Iramework such as Solvency II. The danger however in using a risk
sharing approach is that it may be reIlected in a reduction in the amount oI security on oIIer;
the recalibration oI the SCR and associated Risk Margin would thus lead to increased Iunding
levels.
Peek et al (2008)
1
observed that a contribution commitment by the sponsor could be reIlected
in the pension Iund`s solvency balance sheet in a number oI diIIerent ways. One example could
be Ior the sponsor`s credit rating to be directly reIlected in the calculation oI the SCR by taking
into account Iuture probabilistic solvency oI the sponsoring company. Alternatively, the
sponsor could be allowed to set up the SCR in a separate Iund, instead oI increasing the Iunding
oI the pension Iund itselI. Both approaches would reduce the pension Iund`s SCR. Other
protection mechanisms such as guaranteed protection Iunds (Iire Iunds) as well as allowance
Ior recovery periods might also be taken into consideration.
BeneIit cuts are another way Ior pension Iunds to share risks with plan members. When the
Iunding level oI the pension Iund is below a certain level, in this case 100, the beneIit
payments may be cut. This means that the plan members cover some part oI the losses oI the
pension Iund should the Iunding level oI the pension Iund deteriorate.
Overall, the Solvency II Iunding level oI the pension plans with risk sharing Ieatures is higher
compared to the plans without risk sharing. The amount oI improvement varies depending on
the type oI risk sharing and the associated management rules.
Peek et al summarized the results as Iollows:
Compared to an initial Iunding level oI 100 based on IAS 19 DBO, the application oI
a Solvency II structure would require a dramatic increase in Iunding level Ior pension
Iunds.
SigniIicant changes in asset allocation are necessary in order to reduce SCR (e.g. lower
equity exposure).
The Solvency II methodology makes allowance Ior risk sharing with plan members.
1
Peek, J, Reuss, A, & Scheuenstuhl, G (Eds.). (2008, March). 'Evaluating the Impact of Risk Based Funding Requirements on Pension
Funds`, OECD Working Papers on Insurance and Private Pensions No 16. Retrieved Irom OECD Publishing. website:
http://www.oecd.org/dataoecd///.pdI
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116
This leads to a reduction oI SCR.
The QIS 3 model has to be modiIied in order to account Ior the speciIic risks oI pension
Iunds, in particular regarding inIlation risk and salary increase risk.
Further conceptual work seems necessary in order to properly reIlect risk sharing with
sponsoring company or plan members (e.g. via reduced security level or based on credit
rating oI sponsoring company).
} The quest for greater secur|ty for benef|c|ar|es
The IORP Directive has helped to harmonize the second pillar oI member countries in terms oI
the supply oI suitable Iinancial pension products. It paves the way Ior multinational Iirms to
centralize the investment side oI their pension business by choosing a site Ior their operations
in a single EU-member country. While this will lead to cost savings, the liability side oI the
pension business will remain segmented because IORP`s are obliged to respect Iully the
provisions oI the social and labour law in Iorce in the diIIerent countries where they provide
their services. The Directive championed the cross-border extension oI Ireedom oI choice
between diIIerent types oI pension providers. However, the current application oI the Directive
has resulted in variations in national solvency standards, which has in turn led to regulatory
arbitrage between Member States.
By contrast, the Solvency II approach argues that in a single EU market Ior pensions,
competition should be between providers and the variation oI scheme characteristics,
rather than between supervisory regimes. The Solvency II proposal Ior insurance companies
seeks to bring about consistent and harmonized supervision across the EU with the aim oI
delivering better overall risk management, improved mobility oI workers and a level playing
Iield Ior all pension providers. Solvency II has the potential to bring huge improvements to the
European insurance and pensions industry. It will level the playing Iield by ensuring consistent
regulation in all territories. It oIIers the beneIits oI better capital management by aligning
solvency with the risk proIile oI each Iirm, which in turn will result in better protection Ior
consumers.
The Iundamental debate between these two Iorms oI pension systems is on the level oI security
extended to beneIiciaries. Pension investments diIIer in risk values Irom those oI commercial
insurance undertakings, Ior which Solvency II was intended. Risks Ior pensions are oIten
shared between pension Iunds, employers and employees. Occupational pension Iunds thus do
not oIIer the same level oI protection in terms oI solvency capital saIeguards. Although
IORP`s are not included in the scope oI the Solvency II project, discussions are currently
ongoing as to whether the Solvency II requirements Ior insurance companies should be
extended to pension Iunds as well. To this end, insurers are now lobbying Ior the development
oI an appropriate Iramework to supervise all Iorms oI occupational pensions at the European
level.
The Iact that the implementation oI the IORP and Solvency II Directives has been such a long
process highlights the scale oI the tasks involved. The success to date oI the Directives
demonstrates that harmonisation oI the industry is possible. However with additional Member
States being added to the European project, each oI which is at a diIIerent stage in terms oI
capital regulation, the challenge becomes even greater. Ultimately, the winners in Europe will
be those companies who take the opportunity to really embed the IORP and Solvency II
principles into their corporate culture so as to ensure a better way oI doing business.
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
117
Summary of research findings on EU pension legislation
An interesting statistic revealed itselI when the survey target audience was asked iI they
considered EU legislation with regards the governance oI pension schemes diIIicult to
understand. Diagram 11.1 demonstrates that over 36 oI respondents either agreed or strongly
agreed that this was the case. Surprisingly 54 oI those surveyed voiced no opinion on this
matter; however a more in depth look at these responses revealed that the majority oI these
came Irom UK based pension administrators and represented companies with little or no
activity outside oI UK borders. Those pension Iund representatives oI companies with cross
border activities were Iirmly situated in the agree / strongly agree camp.
Diagram 11.1: Research findings on EU pension IegisIation
EU legislation with regards the governance of cross border pension schemes is difficult to understand.
c. No opinion 12 54.55
b. Agree 5 22.73
a. Strongly agree 3 13.64
d. Disagree 1 4.55
e. Strongly disagree 1 4.55
Total: 22
Source: The Pension Siren - International Pension Survey (2010)
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
118
Part IV
Chapter 12 Asset allocation
Asset allocation is an integral part oI a pension plan structure in that investment returns are
dependent on where and when the assets are actually invested. Asset allocation involves the
distribution oI assets among diIIerent investment choices or classes. The investment allocation
oI the Iund is oIten a traditional mix oI asset classes which would include equities, bonds, cash,
real estate, etc. The main asset classes are thereaIter divided Iurther into subclasses, such as
small-cap stocks or corporate bonds. In addition, alternative asset classes may be employed
using commodities or hedge Iunds.
A} Asset a||ocat|on approaches
Market conditions such as volatility, increasing correlations between markets and lower real
interest rates have highlighted a number oI problems associated with traditional investment
approaches. When equity markets are buoyant, pension Iunds will have overIunded positions,
with more than suIIicient liquidity to meet the plan's Iuture liabilities to members. However, the
recent turbulence in equity markets has exposed some oI the inadequacies in current portIolio
construction techniques. The result has been an erosion oI surpluses and the exposure oI
structural Ilaws in the Iunding levels oI deIined-beneIit pension plans with the value oI assets
being signiIicantly reduced in absolute terms.
Sound investment decision-making is thus oI increasing importance in pension Iund
management. Nowadays the role oI the pension portIolio manager can be likened to that oI the
conductor oI an orchestra, with the unenviable task oI having to keep all assets in concert with
one another in order to deliver to the audience: the pension Iund members.
1. Strategic asset allocation
The primary aim oI a pension asset allocation model is to arrive at a set oI risk and return
parameters that provide the Iund with the necessary returns and liquidity with which to meet
pension liabilities. As such liabilities are typically longer term, an appropriate strategic asset
allocation (SAA) approach is required in order to achieve long-term investment goals and
satisIy the risk based Iunding requirements oI the pension Iund.
An alternative approach to investment decisions is that oI tactical asset allocation (TAA),
which Iocuses on exploiting opportunities in the ever changing capital markets by shiIting the
asset mix temporarily away Irom the normal strategic position.
Inderst (2008)
1
, noted that discussions in the pension industry have intensiIied around the
Iollowing subjects:
What is the right asset allocation strategy Ior pension Iunds?
How should asset allocation decisions be taken, and by whom?
How should the policy be implemented and changed over time?
1
Inderst, G. (Ed.). (2008). INJESTING PENSION PLAN ASSETS. Retrieved Irom IPE.com website: http://www.ipe.com//contents.php
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
119
The asset allocation oI pension Iunds diIIers not only within countries but also between
countries. Many pension Iunds are restricted by law regarding the types oI investments they can
make. Pension Iunds in Anglo-Saxon countries generally invest a larger share oI their assets in
equity and alternative investments than pension Iunds in continental Europe, which tend to opt
Ior a greater weighting in Iixed income securities.
Inderst (2008)
1
observes that asset allocation is inIluenced by a long list oI Iactors, the
importance oI which varies considerably across countries and over time. These include:
Legal constraints (eg, quantitative restrictions imposed by law);
The type oI pension provision (deIined beneIit, deIined contribution, cash balance);
The regulatory regime (eg, Iunding rules or solvency requirements imposed by the
supervisory authorities);
Taxation (oIten diIIerent Ior diIIerent asset classes);
The constitution oI the plan and sponsoring arrangements (public or private sponsor;
industry-wide plans);
The size oI the pension Iund and strength oI the sponsor;
Accounting standards;
The membership proIile;
Advice given by actuaries, investment consultants, Iund managers;
Risk tolerance oI pension Iund trustees and sponsors;
The pensions investment culture and history.
The SAA approach will also diIIer depending on the pension model employed by the scheme
provider; thus pension plans that conduct their aIIairs under the Solvency II model have greater
risk based Iunding requirements than their IORP counterparts.
2. Multi asset allocation
Fund managers may propose a multi asset allocation model to Iund sponsors, wherein a
selection oI assets is oIIered across a range oI classes. This model can be managed either
dynamically or strategically depending upon how the Iund manager views the market
landscape. A dynamic management approach may have an equity allocation ranging Irom zero
to 70 investment in equities. The Iund manager would act according to the yield, in that a
negative or positive result over a six month cycle could have the portIolio asset allocation
altered to reIlect the changing market conditions. The asset allocation decision in a bullish or
bearish market is thereIore a key Iactor in delivering results.
} The |nf|uence of cu|ture on asset a||ocat|on
HoIstede (1980)
2
deIined national culture as 'the values, belieIs, and assumptions that are
learned in early childhood and distinguish one group oI people Irom another. HoIstede
identiIied Iour work-related value-based cultural dimensions that have an eIIect on the way
people behave. These are as Iollows:
1
Inderst, G. (Ed.). (2008). INJESTING PENSION PLAN ASSETS. Retrieved Irom IPE.com website: http://www.ipe.com//contents.php
2
HoIstede, G. (1980). Cultures Consequences . International Differences in Work-Related Jalues. Newbury Park, CA: Sage.
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
120
Uncertainty Avoidance (UAI)
Power Distance (PDI)
Masculinity-Femininity (MAS)
Individualism-Collectivism (IDV)
A IiIth cultural dimension associated with long term orientation` (LTO) emerged through
additional observational research which distinguished between the values oI thriIt and
perseverance, as opposed to those oI short-term orientation` such as respect Ior tradition,
IulIilling social obligations, and protecting one's image (HoIstede and Bond,1988)
1
.
Culture inIluences how individuals and institutions respond to changes and to economic
opportunities. The cultural dimensions model can be used to help explain variations in the asset
allocation oI pension Iunds across EU Member States. De Bruijne (2005)
2
tested the
hypothesis that:
'In countries with a higher uncertainty avoidance index (UAI), pension Iunds will invest less in
equity than in countries with lower uncertainty avoidance index.
Uncertainty avoidance is a measure oI a society's tolerance Ior uncertainty and ambiguity in
terms oI an unknown Iuture. The results oI the research showed that the Anglo-Saxon and
Germanic countries oI Europe regarded uncertainty in society and the Iuture as an unavoidable
Iact. This cultural position is reIlected in a greater willingness to take risks. In countries that
scored high on the UAI, such as France, Belgium and Greece uncertainty is experienced as a
permanent threat that must be mitigated through control and regulation (see diagram below).
Diagram 12.1: Hofstede's vaIue-based cuIturaI dimensions
Uncertainty Avoidance Index
Flexible Rules / Regulations
Pragmatic Conservative
Gamble Control
Source: de Bruijne - ING Group (2005)
1
HoIstede, G., & Bond, M. H. (1988). The ConIucius connection: Irom cultural roots to economic growth. Organi:ational Dvnamics,
Jol.16(No.4), 4-21.
2
de Bruijne, P., Dr. (2005, May 29). ING Group and Pension Funds.International Differences. Lecture presented at Armenian International
Policy Research Group, Tsakhkadzor, Armenia.
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
120
Uncertainty Avoidance (UAI)
Power Distance (PDI)
Masculinity-Femininity (MAS)
Individualism-Collectivism (IDV)
A IiIth cultural dimension associated with long term orientation` (LTO) emerged through
additional observational research which distinguished between the values oI thriIt and
perseverance, as opposed to those oI short-term orientation` such as respect Ior tradition,
IulIilling social obligations, and protecting one's image (HoIstede and Bond,1988)
1
.
Culture inIluences how individuals and institutions respond to changes and to economic
opportunities. The cultural dimensions model can be used to help explain variations in the asset
allocation oI pension Iunds across EU Member States. De Bruijne (2005)
2
tested the
hypothesis that:
'In countries with a higher uncertainty avoidance index (UAI), pension Iunds will invest less in
equity than in countries with lower uncertainty avoidance index.
Uncertainty avoidance is a measure oI a society's tolerance Ior uncertainty and ambiguity in
terms oI an unknown Iuture. The results oI the research showed that the Anglo-Saxon and
Germanic countries oI Europe regarded uncertainty in society and the Iuture as an unavoidable
Iact. This cultural position is reIlected in a greater willingness to take risks. In countries that
scored high on the UAI, such as France, Belgium and Greece uncertainty is experienced as a
permanent threat that must be mitigated through control and regulation (see diagram below).
Diagram 12.1: Hofstede's vaIue-based cuIturaI dimensions
Uncertainty Avoidance Index
Flexible Rules / Regulations
Pragmatic Conservative
Gamble Control
Source: de Bruijne - ING Group (2005)
1
HoIstede, G., & Bond, M. H. (1988). The ConIucius connection: Irom cultural roots to economic growth. Organi:ational Dvnamics,
Jol.16(No.4), 4-21.
2
de Bruijne, P., Dr. (2005, May 29). ING Group and Pension Funds.International Differences. Lecture presented at Armenian International
Policy Research Group, Tsakhkadzor, Armenia.
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
120
Uncertainty Avoidance (UAI)
Power Distance (PDI)
Masculinity-Femininity (MAS)
Individualism-Collectivism (IDV)
A IiIth cultural dimension associated with long term orientation` (LTO) emerged through
additional observational research which distinguished between the values oI thriIt and
perseverance, as opposed to those oI short-term orientation` such as respect Ior tradition,
IulIilling social obligations, and protecting one's image (HoIstede and Bond,1988)
1
.
Culture inIluences how individuals and institutions respond to changes and to economic
opportunities. The cultural dimensions model can be used to help explain variations in the asset
allocation oI pension Iunds across EU Member States. De Bruijne (2005)
2
tested the
hypothesis that:
'In countries with a higher uncertainty avoidance index (UAI), pension Iunds will invest less in
equity than in countries with lower uncertainty avoidance index.
Uncertainty avoidance is a measure oI a society's tolerance Ior uncertainty and ambiguity in
terms oI an unknown Iuture. The results oI the research showed that the Anglo-Saxon and
Germanic countries oI Europe regarded uncertainty in society and the Iuture as an unavoidable
Iact. This cultural position is reIlected in a greater willingness to take risks. In countries that
scored high on the UAI, such as France, Belgium and Greece uncertainty is experienced as a
permanent threat that must be mitigated through control and regulation (see diagram below).
Diagram 12.1: Hofstede's vaIue-based cuIturaI dimensions
Uncertainty Avoidance Index
Flexible Rules / Regulations
Pragmatic Conservative
Gamble Control
Source: de Bruijne - ING Group (2005)
1
HoIstede, G., & Bond, M. H. (1988). The ConIucius connection: Irom cultural roots to economic growth. Organi:ational Dvnamics,
Jol.16(No.4), 4-21.
2
de Bruijne, P., Dr. (2005, May 29). ING Group and Pension Funds.International Differences. Lecture presented at Armenian International
Policy Research Group, Tsakhkadzor, Armenia.
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
121
Through the testing oI the hypotheses, de Bruijne observed the impact oI cultural Iactors on
asset allocation in terms oI those countries that demonstrated a high degree oI uncertainty
avoidance in their behavior. These European countries tended to opt Ior a relatively lower
equity weighting oI 55 in their portIolios` compared to their Anglo Saxon counterparts,
which at the time preIerred a 65 exposure.
C) A current v|ew of pens|on fund asset a||ocat|on
A recent survey by Towers Watson (2010)
1
displays the evolution oI pension Iunds in a select
number oI Western European countries in terms oI assets under management over the last 10
years (see table 12.1 below).
1. European pension fund asset evolution 1999 - 2009
The survey revealed the roller-coaster` eIIect that the upheaval in the marketplace had Ior the
level oI Iunds under management.
TabIe 12.1: European pension fund asset evoIution 1999 - 2009 - EUR biIIion
1oLal AsseLs 1oLal AsseLs
MarkeL Lu8 (bllllon) Lu8 (bllllon)
?ear-end 1999 ?ear-end 2009
lrance 38 140
Cermany 148 323
lreland 39 80
neLherlands 314 779
uk 1091 1410
1oLal (Lu8) 1630 2732
Source: Adopted from Towers Watson global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
2. European pension fund asset evolution 2007 - 2009
Towers Watson recorded that the value oI European pension assets at the end oI 2009 was EUR
2,732 billion, aIter having recovered Irom the 2008 collapse in the stock markets. The 2008
Iigures were almost EUR 800 billion or 25 lower than 2007(see Table 12.2). The drop in
assets between 2007 and 2008 was largely explained by the poor perIormance oI markets
around the world and the high exposure oI pension Iunds to equities. By the same token, the
recovery in assets under management can be put down to the revival oI the markets in 2009 and
the high Iund exposure to equities; assets however are still well below levels achieved at the
end oI December 2007.
1
Towers Watson. (2010, January). Global Pension Asset Studv . Retrieved Irom Towers Watson website: http://www.towerswatson.com/
assets///.pdI
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
122
TabIe 12.2: European pension fund asset evoIution 2007 - 2009 - EUR biIIion
1oLal AsseLs 1oLal AsseLs 1oLal AsseLs
MarkeL Lu8 (bllllon) Lu8 (bllllon) Lu8 (bllllon)
?ear-end 2007 ?ear-end 2008 ?ear-end 2009
lrance 127 113 140
Cermany 273 284 323
lreland 93 63 80
neLherlands 743 649 779
uk 1983 1306 1410
1oLal (Lu8) 3223 2419 2732
Source: Adopted from Towers Watson global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
3. The evolution of European pension assets
The European countries oI those surveyed which managed to retrieve and surpass the 2007
levels oI pension Iunds assets under management by the end oI 2009 were France, Germany
and the Netherlands (see Diagram 12.2 below). These countries had a much lower exposure to
equities throughout 2007 - 8, thus conIirming that cultures which are more conservative in their
approach to asset allocation can avoid pitIalls by steering clear oI uncertainty.
Diagram 12.2: The evoIution of European pension assets
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
The pension survey highlighted that the issues Iacing global pension markets amid the Iinancial
crisis included liquidity, the management oI credit/collateral risk and asset manager
underperIormance along with the new challenges in strategic asset allocation.
4. Diversification
The Towers Watson survey results showed that many pension Iunds seek to pursue a wider
range oI asset strategies in order to diversiIy their portIolios. Property is by Iar the most
popular alternative to equities and bonds, though the proportion oI Iunds investing in this asset
class dropped during 2009 Irom 25 to 20 in the UK. A larger proportion oI Continental
European Iunds continue to invest in property despite the recent collapse. UK pension Iunds
have historically invested in domestic property markets. However, given the current depressed
value oI property on British shores, Iunds are beginning to look Iurther aIield to international
markets in an attempt to enhance returns.
lrance
Cermany
lreland
neLherlands
uk
Luropean pens|on assets
Lvo|ut|on 1999-2009 - LUk b||||on
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
122
TabIe 12.2: European pension fund asset evoIution 2007 - 2009 - EUR biIIion
1oLal AsseLs 1oLal AsseLs 1oLal AsseLs
MarkeL Lu8 (bllllon) Lu8 (bllllon) Lu8 (bllllon)
?ear-end 2007 ?ear-end 2008 ?ear-end 2009
lrance 127 113 140
Cermany 273 284 323
lreland 93 63 80
neLherlands 743 649 779
uk 1983 1306 1410
1oLal (Lu8) 3223 2419 2732
Source: Adopted from Towers Watson global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
3. The evolution of European pension assets
The European countries oI those surveyed which managed to retrieve and surpass the 2007
levels oI pension Iunds assets under management by the end oI 2009 were France, Germany
and the Netherlands (see Diagram 12.2 below). These countries had a much lower exposure to
equities throughout 2007 - 8, thus conIirming that cultures which are more conservative in their
approach to asset allocation can avoid pitIalls by steering clear oI uncertainty.
Diagram 12.2: The evoIution of European pension assets
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
The pension survey highlighted that the issues Iacing global pension markets amid the Iinancial
crisis included liquidity, the management oI credit/collateral risk and asset manager
underperIormance along with the new challenges in strategic asset allocation.
4. Diversification
The Towers Watson survey results showed that many pension Iunds seek to pursue a wider
range oI asset strategies in order to diversiIy their portIolios. Property is by Iar the most
popular alternative to equities and bonds, though the proportion oI Iunds investing in this asset
class dropped during 2009 Irom 25 to 20 in the UK. A larger proportion oI Continental
European Iunds continue to invest in property despite the recent collapse. UK pension Iunds
have historically invested in domestic property markets. However, given the current depressed
value oI property on British shores, Iunds are beginning to look Iurther aIield to international
markets in an attempt to enhance returns.
Luropean pens|on assets
Lvo|ut|on 1999-2009 - LUk b||||on
2009
1999
0 1000 2000 3000 4000
lrance
Cermany
lreland
neLherlands
uk
1oLal (Lu8)
Luropean pens|ons assets
Lvo|ut|on 2007 - 2009 LUk b||||on
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
122
TabIe 12.2: European pension fund asset evoIution 2007 - 2009 - EUR biIIion
1oLal AsseLs 1oLal AsseLs 1oLal AsseLs
MarkeL Lu8 (bllllon) Lu8 (bllllon) Lu8 (bllllon)
?ear-end 2007 ?ear-end 2008 ?ear-end 2009
lrance 127 113 140
Cermany 273 284 323
lreland 93 63 80
neLherlands 743 649 779
uk 1983 1306 1410
1oLal (Lu8) 3223 2419 2732
Source: Adopted from Towers Watson global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
3. The evolution of European pension assets
The European countries oI those surveyed which managed to retrieve and surpass the 2007
levels oI pension Iunds assets under management by the end oI 2009 were France, Germany
and the Netherlands (see Diagram 12.2 below). These countries had a much lower exposure to
equities throughout 2007 - 8, thus conIirming that cultures which are more conservative in their
approach to asset allocation can avoid pitIalls by steering clear oI uncertainty.
Diagram 12.2: The evoIution of European pension assets
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
The pension survey highlighted that the issues Iacing global pension markets amid the Iinancial
crisis included liquidity, the management oI credit/collateral risk and asset manager
underperIormance along with the new challenges in strategic asset allocation.
4. Diversification
The Towers Watson survey results showed that many pension Iunds seek to pursue a wider
range oI asset strategies in order to diversiIy their portIolios. Property is by Iar the most
popular alternative to equities and bonds, though the proportion oI Iunds investing in this asset
class dropped during 2009 Irom 25 to 20 in the UK. A larger proportion oI Continental
European Iunds continue to invest in property despite the recent collapse. UK pension Iunds
have historically invested in domestic property markets. However, given the current depressed
value oI property on British shores, Iunds are beginning to look Iurther aIield to international
markets in an attempt to enhance returns.
3000 4000
Luropean pens|ons assets
Lvo|ut|on 2007 - 2009 LUk b||||on
2009
2008
2007
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
123
An additional Iactor to consider when purchasing international property and other assets which
are globally distributed is the control oI currency risk. The proportion oI Iunds using active
currency management in the UK has increased Irom 7 to 8. In Continental Europe and
Ireland, this proportion is 4. Tactical Asset Allocation (TAA) has also gained traction in the
UK, with the proportion oI Iunds using this investment approach increasing Irom 2 to 5. In
Continental Europe and Ireland, 3 oI Iunds have exposure to TAA. Both active currency and
TAA are expected to grow in popularity over the next year.
DiversiIication into alternative assets which included property and derivatives continued in
2009. The Towers Watson research revealed that as oI the end oI 2009 pension portIolios in
the UK and Ireland had a larger proportion oI Iunds allocated to risky` assets, whereas the
Netherlands and France adopted more conservative investment strategies with the emphasis on
bonds as opposed to equities. This marked shiIt Irom equities to bonds was largely as a result oI
the poor perIormance oI stock markets over 2009 coupled with a more conservative attitude by
the Netherlands, France and Germany towards portIolio management.
Diagram 12.3: European pension fund asset cIass breakdown 2009
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
Diagram 12.3 illustrates the diversiIied investment strategy oI pension Iunds with a mixture oI
shares, bonds and investment Iunds being held by a select number oI countries. The pension-
Iund asset allocation diIIers signiIicantly across countries thus reIlecting the diversity oI
individual legal and regulatory regimes. Investments in the bond market remain the pre-
dominant option Ior pension Iunds in Continental European countries. It is envisaged that the
trend towards reIuge in bonds will continue due to growing interest in liability hedging and de-
risking strategies. To this end the structure oI bond portIolios and associated benchmarks are
increasingly being used as a risk management tool in Europe. Meanwhile, exposure to cash and
other alternative assets has continued to grow, extending an established trend and reIlecting
pension Iunds` growing appetite Ior diversiIication.
Irish institutional investors remain more heavily invested in equities than their European peers,
with a lower weighting in lower-risk bonds. Despite the small size oI the Irish Stock Exchange
in global terms, Irish investors have a higher average exposure to domestic equities than any oI
the other countries surveyed across Europe.
28
lrance
Cermany
lreland
neLherlands
uk
Asset A||ocat|on 2009
LqulLles
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
123
An additional Iactor to consider when purchasing international property and other assets which
are globally distributed is the control oI currency risk. The proportion oI Iunds using active
currency management in the UK has increased Irom 7 to 8. In Continental Europe and
Ireland, this proportion is 4. Tactical Asset Allocation (TAA) has also gained traction in the
UK, with the proportion oI Iunds using this investment approach increasing Irom 2 to 5. In
Continental Europe and Ireland, 3 oI Iunds have exposure to TAA. Both active currency and
TAA are expected to grow in popularity over the next year.
DiversiIication into alternative assets which included property and derivatives continued in
2009. The Towers Watson research revealed that as oI the end oI 2009 pension portIolios in
the UK and Ireland had a larger proportion oI Iunds allocated to risky` assets, whereas the
Netherlands and France adopted more conservative investment strategies with the emphasis on
bonds as opposed to equities. This marked shiIt Irom equities to bonds was largely as a result oI
the poor perIormance oI stock markets over 2009 coupled with a more conservative attitude by
the Netherlands, France and Germany towards portIolio management.
Diagram 12.3: European pension fund asset cIass breakdown 2009
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
Diagram 12.3 illustrates the diversiIied investment strategy oI pension Iunds with a mixture oI
shares, bonds and investment Iunds being held by a select number oI countries. The pension-
Iund asset allocation diIIers signiIicantly across countries thus reIlecting the diversity oI
individual legal and regulatory regimes. Investments in the bond market remain the pre-
dominant option Ior pension Iunds in Continental European countries. It is envisaged that the
trend towards reIuge in bonds will continue due to growing interest in liability hedging and de-
risking strategies. To this end the structure oI bond portIolios and associated benchmarks are
increasingly being used as a risk management tool in Europe. Meanwhile, exposure to cash and
other alternative assets has continued to grow, extending an established trend and reIlecting
pension Iunds` growing appetite Ior diversiIication.
Irish institutional investors remain more heavily invested in equities than their European peers,
with a lower weighting in lower-risk bonds. Despite the small size oI the Irish Stock Exchange
in global terms, Irish investors have a higher average exposure to domestic equities than any oI
the other countries surveyed across Europe.
33
32
39
28
60
46
62
24
48
31
12
4
7
24
6
10
2
10
1
3
Asset A||ocat|on 2009
LqulLles 8onds Cash CLher
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
123
An additional Iactor to consider when purchasing international property and other assets which
are globally distributed is the control oI currency risk. The proportion oI Iunds using active
currency management in the UK has increased Irom 7 to 8. In Continental Europe and
Ireland, this proportion is 4. Tactical Asset Allocation (TAA) has also gained traction in the
UK, with the proportion oI Iunds using this investment approach increasing Irom 2 to 5. In
Continental Europe and Ireland, 3 oI Iunds have exposure to TAA. Both active currency and
TAA are expected to grow in popularity over the next year.
DiversiIication into alternative assets which included property and derivatives continued in
2009. The Towers Watson research revealed that as oI the end oI 2009 pension portIolios in
the UK and Ireland had a larger proportion oI Iunds allocated to risky` assets, whereas the
Netherlands and France adopted more conservative investment strategies with the emphasis on
bonds as opposed to equities. This marked shiIt Irom equities to bonds was largely as a result oI
the poor perIormance oI stock markets over 2009 coupled with a more conservative attitude by
the Netherlands, France and Germany towards portIolio management.
Diagram 12.3: European pension fund asset cIass breakdown 2009
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
Diagram 12.3 illustrates the diversiIied investment strategy oI pension Iunds with a mixture oI
shares, bonds and investment Iunds being held by a select number oI countries. The pension-
Iund asset allocation diIIers signiIicantly across countries thus reIlecting the diversity oI
individual legal and regulatory regimes. Investments in the bond market remain the pre-
dominant option Ior pension Iunds in Continental European countries. It is envisaged that the
trend towards reIuge in bonds will continue due to growing interest in liability hedging and de-
risking strategies. To this end the structure oI bond portIolios and associated benchmarks are
increasingly being used as a risk management tool in Europe. Meanwhile, exposure to cash and
other alternative assets has continued to grow, extending an established trend and reIlecting
pension Iunds` growing appetite Ior diversiIication.
Irish institutional investors remain more heavily invested in equities than their European peers,
with a lower weighting in lower-risk bonds. Despite the small size oI the Irish Stock Exchange
in global terms, Irish investors have a higher average exposure to domestic equities than any oI
the other countries surveyed across Europe.
4
6
10
2
10
1
3
The development of pension systems in Europe and the role of governance, risk management and external consultants
in the change process
124
Pension Iunds in the Netherlands displayed a signiIicantly lower exposure to equities and
higher allocation to bonds in their asset allocation. As a result, they experienced a lower decline
in assets during 2009 than those with higher equity allocation. On the other hand, the UK who
displayed an above-average allocation to equities, suIIered Irom the collapse in the markets
during 2008, but also recovered positions Iaster throughout 2009 as a result oI greater equity
exposure (see Diagram 12.4 below). It is also envisaged that exposure to active currency and
tactical asset allocation will increase this year, as Iunds seek to diversiIy their risk
Diagram 12.4: Pension asset aIIocation in the NetherIands and the UK
Source: Adopted from Towers Watson and various secondary sources (2010)
5. European pension funds under management versus GDP
The ratio oI pension assets to GDP Iell signiIicantly over 2009, with Ireland, the Netherlands,
and the UK all experiencing dramatic reductions on their 2008 levels. The longer trend is oI
particular concern given that both Ireland and the UK are well below 1999 ratio levels (see
Diagram 12.5 below). Such low Iigures iI not addressed imminently could have a damaging
eIIect on the Iuture spending power and therein economies oI these countries.
Diagram 12.5: European pension funds under management versus GDP 2009
Source: Adopted from Towers Watson and various secondary sources - Global pension asset study (2010)
*Note: UK Iigures exclude personal and stakeholder DC assets
GDP values Irom IMF, taken in USD at current prices
0
20
40
60
80
100
uec
1999
uec
2004
uec
2009
Nether|ands - ens|on assets a||ocat|on
lrance
1999 3
2009 6
0
30
100
130
o
f
G
D